Protecting your private information is our priority. This Statement of Privacy applies to Coinflow Labs Limited and CF Labs (Coinflow, we, us, our) and governs Personal Data collection and usage. For the purposes of this Privacy Notice, unless otherwise noted, all references to Coinflow include both Coinflow Labs Limited and CF Labs Ltd. The Coinflow application is a technology application.
CF Labs (established in Malta EU) is a wholly owned subsidiary of Coinflow Labs Limited (established in the U. S.)
Your Personal Data is either submitted to us via your employer/ contracting party which acts as a "Controller" (defining the Purposes and Scope of Personal Data Processing Activities to be carried out by us) or yourself upon becoming a user of our platform. Therefore, we undertake the Processing of your Personal Data either under a Contractual Obligation towards a Controller or with your Consent in registering into our platform.
The Purpose and Scope of Coinflow Services and inherent Processing of Personal Data
Collection of Your Personal Data/ Personal Information
We do not collect any Personal Data about you unless your employer or you provide it to us. However, you may be required to provide certain Personal Data to us when you elect to use certain products or services. These may include:
- (a) registering for an account;
- (d) sending us an email message;
- (e) submitting your credit card or other payment information when ordering and purchasing products and services;
The categories of Personal Data pertaining to you that we Process consist of:
- Identification Data – name, company, other;
- Contact Data – corporate address, corporate email, other
- Financial Data – transactions, card information, IBAN, other
We use your contact identification, and financial information for the purpose of communicating with you in relation to services and/or products we render to you and/or you have requested from us, this occurs either while under a Contractual Obligation or Legitimate Interest by our part (provided it does not collide with our Rights and Freedoms as determined under applicable law).
Additionally, we may collect additional Personal Data, such as online identifiers, IP addresses, and country, to enable our services to you or fulfil a Legal Obligation.
Sharing Information with Third Parties
Coinflow does not sell, rent, or lease Personal Data to 3rd parties.
Coinflow solely shares Personal Data with those providers that act as Processors before Coinflow, meaning they deliver a part of the Services we deliver to you.
Coinflow resorts to the following Processors:
- Render for the hosting of our IT Landscape;
- MogoDB as the database service provider;
- Nsure assures legally required anti-fraud assessment
- Oscilar assures legally required anti money laundering assessment
- Wordpay credit card payment processor
- Sumsub for identity verification towards users
- Persona for identity verification towards users
- Nuvei credit card payment processor
- Shift4 credit card payment processor
Coinflow may disclose your Personal Data, without notice, if required to do so by law or in the good faith belief that such action is necessary to:
- (a) conform to the edicts of the law or comply with legal process served on Coinflow or the site;
- (b) protect and defend the rights or property of Coinflow; and/or
- (c) act under exigent circumstances to protect the personal safety of users of Coinflow, or the public.
Some of our Processors are established outside of the European Union or the UK, which means your Personal Data will be transferred to a 3rd country. In such cases we ensure that those Processors have entered into contractual clauses that ensure the security and confidentiality of your Personal Data and they have in place adequate Technological and Operational measures that meet the requirements posed under the law.
Additionally, your Personal Data may be collected and Processed via Cookies or Trackers, which are a form of automated Processing by 3rd parties.
You may find information relating to Cookies on our Cookie Management Tool and disable those Cookies which are not flagged as "necessary"; meaning Cookies that are not vital for the operation of the website and the delivering of our Services towards your and our Corporate Clients.
Your Rights under the law
Depending on where you are located or reside, you may have certain rights regarding the Personal Data we maintain about you and certain choices about what Personal Data we collect from you, how we use it, and how we communicate with you. Such rights may include the rights to:
- Access Your Personal Data: Receive confirmation of processing and request access to the Personal Data we maintain about you. Most of your Personal Data can be accessed and exported by logging into your account. Where provided by applicable law, you may request that we include a description of the purpose of the processing of your personal data, third parties with which your data has been shared, and information regarding the safeguards for international data transfer.
- Correct Your Personal Data: Request to update and correct inaccuracies in your Personal Data. Most of your Personal Data can be accessed and corrected by logging into your account and accessing your account settings.
- Delete Your Personal Data: Request that Coinflow delete all Personal Data we maintain about you including your account and the Voice Data associated with your account. This deletion also includes the personal data processed under the legal basis of consent. Where provided by applicable law, you may request that your Personal Data be anonymized rather than deleted.
- Restrict or Object To Processing of Your Personal Data: Restrict or object to the processing of your Personal Data, where applicable.
- Request Portability of Your Personal Data: Request to transfer your Personal Data to another authorized organization.
- Withdraw Consent: You may withdraw any consent you previously provided to us regarding the processing of your Personal Data at any time. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdraw your consent. The Voice Library Addendum provides more information about consent withdrawals in the context of the Voice Library.
- Unsubscribe from Marketing Communications: You may unsubscribe from receiving marketing communications at any time by following the instructions contained within the relevant email. Please be aware that if you opt out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take some time for us to process your request and you may receive promotional communications from us that you have opted out from during that period, to the extent permitted by applicable law. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our Services.
- Anonymization. To the extent provided by law, you may ask to have your Personal Data anonymized. In such case, where anonymization is not feasible, we will inform you as to the reasons why such anonymization is not feasible. To have your Personal Data anonymized means the Personal Data will be processed in a manner such that it is not possible to associate such information with you, directly or indirectly.
- Right to Information About Shared Entities. To the extent provided by law, you may have rights to be informed about other companies with which we share your Personal Data.
- Right to file a complaint: If you feel that your rights are infringed, you have the right to file a complaint with the Malta Office of the Information and Data Protection Commissioner at the following website https://idpc.org.mt/file-a-complaint/.
To submit a verifiable request, please contact us at support@coinflowlabs.app.
Please note that we may not be able to comply with requests to delete your Personal Data if and while it is necessary to:
- Complete the transaction for which the Personal Data was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with an existing legal obligation; or
- Otherwise use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information.
Children Under Eighteen
Coinflow does not knowingly collect Personal Data from children under the age of eighteen. If you are under the age of eighteen, by law you are not allowed to use our services. If we become aware that we are Processing Personal Data pertaining to a child, we will take immediate steps to delete such information as soon as possible and potentially inform the relevant authorities.
Changes to this Statement
Coinflow reserves the right to change this Privacy Notice from time to time. Your continued use of the application and/or services available after such modifications will constitute your:
- (a) acknowledgment of the modified Privacy Notice; and
- (b) agreement to abide and be bound by that Notice.
Contact Information
Data related to the Controllers under this Notice: