Last Updated 10th October 2018
We at Nouvive understand that one of the many reasons you choose to enter Cryptocurrency/Crypto Asset Market is to protect and secure your private details. Even though we understand this, in the EU we have to still secure ourselves by means of GDPR regulation.
The little data that we collect are to do one of two things:
Internal Data Analysis
o Our web pages and e-mails may contain web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence. Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However where your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.
Market Sentiment Analysis
o We may from time to time use personal information about you to form profiles about the market so that we can understand the crypto market as a whole and provide the very best products and services we can. We may need to do this either to perform our legal obligations or because it is in our legitimate interest to use your personal information in such a way.
For the purpose of the applicable data protection legislation (meaning, prior to 25 May 2018 the Data Protection Act 1998 and from 25 May 2018 the General Data Protection Regulation and any legislation which implements it) (the “Data Protection Legislation”), the data controller is Aeries Hadson Limited under company number 10877977of 220 Edgware Road, London, W2 1EG.
References in this Privacy and Cookies Policy and on our website to “we”, “our” or “us” are references to Aeries Hadson Limited or representatives. References to “you” and “your” means each person who interacts with us, uses our website or the products and services we provide.
1. Information we collect and process about you
1.1 We may collect and process the following personal data about you:
1.1.1 Information you give to us. You may give us information about you when you register on our website nouvive.com or by communicating with us by phone, email or otherwise. This also includes information you provide when you subscribe to any of our services, participate in surveys and user forums, and when you give us any feedback or report a problem with our website. The information you give us may include your name, address, email address, phone number, date of birth, identity documents, username, password, job title and company information.
1.1.2 Information we collect about you when you communicate with us by phone, email, post, or otherwise, and when you use our products and services. We collect information such as how and when you contacted us and responded to communications from us and about how and when you use our products and services.
1.1.3 Information we collect about you if you use our website or interact with us over the internet, including via social media. Each time you visit our website or interact with us we may automatically collect the following information: (a) technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; (b) information about your visit, including the full Uniform Resource Locators (URL); products you viewed or searched for; length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).
1.1.4 Information we collect about you from publicly available sources. This may include information available from social media (depending on your settings and the applicable privacy policies) and information from resources such as Companies House.
1.1.5 Information we receive from other sources. We may receive further information about you if you use any of the services we provide. We work closely with third parties (including, for example, suppliers, service providers, identity verification providers) and may receive information about you from them. We may combine information we receive from these other sources with information you give to us and information we collect about you.
1.1.6 We may monitor or record telephone conversations or other communications between you and us and keep recordings or transcripts of them and we may keep a copy of any correspondence.
1.2 We also collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal data, but it is not considered personal data under the Data Protection Legislation as it does not directly or indirectly identify you. If at any time we do combine any aggregated data with your personal data so that it can identify you, we treat the combined data as personal data, which we will use and process in accordance with this Privacy and Cookies Policy.
2.1 We and our service providers collect information about your use of our website from cookies. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once it is it helps analyse website traffic or lets us know when you visit a particular site. Cookies allow website applications to respond to you as an individual. The website application can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.
2.2 We use traffic log cookies to identify which of our website pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from our system.
2.3 Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
2.4 You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
3. Purposes and legal basis for using your personal data
3.1 Where you have requested that we provide a specific product or service to you, or you otherwise make use of those products or services, we will process your personal data in order to perform our contract with you and provide that product or service.
3.2 We also use the personal data we hold about you to pursue our legitimate interests in providing and marketing our products and services to you, improving our website, services, and interactions with you and other users of our products and services in the following ways:
3.2.1 administer your account and relationship with us and to communicate with you by telephone, mail, email, text (SMS) message, instant messaging or other electronic means;
3.2.2 verify your identity and detect fraud and crime and comply with any legal or regulatory requirements;
3.2.3 provide you with information about the products and services that you request from us;
3.2.4 provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
3.2.5 provide you with information about products or services we feel may interest you or be best for you;
3.2.6 your data may be shared with product or service providers to validate if you are an existing customer (which may affect whether you can be accepted for one of their products) or for fraud prevention purposes. The product or service provider does not have permission to use these data for any other purpose including marketing.
3.2.7 notify you about changes to our services;
3.2.8 ensure that content from our website is presented in the most effective manner for you and your device;
3.2.9 to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
3.2.10 to build up a picture of your interests so that you don’t miss information relevant to you when you visit our website;
3.2.11 to improve the service we offer you and to try and ensure that you get the best from our website;
3.2.12 to allow you to participate in interactive features of our website and services;
3.2.13 as part of our efforts to keep our website safe and secure;
3.2.14 to measure the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
3.2.15 to send direct marketing to you (see section 5, below);
3.2.16 to make suggestions and recommendations about products or services that we think may be of interest based on usage patterns both on our website and on other channels (such as email and social media);
3.2.17 for training and quality purposes;
3.2.18 to check any instructions you give to us and for the purposes of investigating any complaint you may make, or as evidence in any dispute or anticipated disputes between you and us.
3.3 In some cases we may also use the personal data we hold about you to comply with our legal obligations, or enter into or perform a contract with you.
4. Who your data can be disclosed to
4.1 We may need to disclose your data to others to ensure the effective provision to you of the products, services, and information you request. Your data may also be disclosed to the other entities as described below.
4.2 We may share your personal information with any member of our group. We currently only have subsidiaries, but from time to time this may also include any holding company we have and their subsidiaries.
4.3 We may share your information with selected third parties including:
4.3.1 Suppliers, service providers, business partners, and sub-contractors;
4.3.2 Fraud prevention agencies, to prevent crime and trace those responsible;
4.3.3 Identity verification providers, to comply with legal or regulatory requirements;
4.3.4 Analytics and search engine providers that assist us in the improvement and optimisation of our website;
4.3.5 IT and software providers who supply us with our IT infrastructure for the provision of our services and administering our business (including our internal and external communications) and who also help us manage our customer and contact databases, customer relationships and marketing.
4.4 We may disclose your personal information to third parties if:
4.4.1 we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
4.4.2 Aeries Hadson Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
4.4.3 we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with you and other agreements; or to protect the rights, property, or safety of our business, our customers, or others.
4.5 We review all our relationships with third parties carefully so that we can be sure as possible that their practices match our own commitments to you relating to privacy and security. We also comply with the Data Protection Legislation in our dealings with these third parties to ensure that your information is appropriately protected.
5. Direct marketing and how you can change your preference
5.1 We may send direct marketing communications to you, including by email, telephone or SMS or mail. If we are required by law to have your consent to do this then we will only do so if we have that consent.
5.2 Whenever you receive direct marketing from us you will be told how you can unsubscribe so that you no longer receive it. When we communicate with you via email you will also be given the opportunity to set or amend any preferences that you have indicated to us.
5.3 Sometimes we may need to contact you further to ask you for additional information so that we can comply with your request.
6. Where we store and transfer your data
6.1 Where we store your information ourselves it is stored on our secure servers in the EU. However, where we share your information with third parties this may involve transferring it to a country outside the EU and the European Economic Area (EEA). This may include countries that do not have data protection laws which are as strong as those in the UK or EU. Where we do this we will take the steps required under the Data Protection Legislation to ensure that your information is appropriately protected. If you would like any further information about this then please contact us using the details in the Contact section below.
6.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access, loss or damage.
7. How long we keep your information for
7.1 How long we keep your information will depend on the purpose for which we use it. We will only retain your information for as long as is necessary for the purposes set out in this Privacy and Cookies Policy and as is necessary to comply with our legal obligations. We do not keep more information than we need for the particular purpose.
7.2 Where we have provided you with a product or service we will keep an archived record of your personal data for a period of up to 6 years after termination (unless a longer period is prescribed by law) for the purposes of responding to legal disputes and legal or regulatory enquiries or investigations only, but will not use this data for any other purpose.
7.3 If you ask us to stop sending direct marketing communications to you, we will keep the minimum amount of information necessary (such as your name and email address) to ensure that we are able to adhere to your request.
8. Third party websites
8.1 Our website may contain links to other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these websites.
9. Your rights
9.1 Under the Data Protection Legislation, you have certain rights in respect of the personal data we hold about you. These may include rights to: request a copy of the personal data that we hold, request that we correct personal data if it is inaccurate, request that we erase or block your personal data, and to object to our processing of your personal data. These rights are limited in some situations. For example, if we have a legal requirement or a compelling legitimate ground we may continue to process your data even where you request its deletion.
9.2 If you would like to exercise any of these rights, please contact us using the details in the Contact section below.
9.3 You also have the right to make a complaint if you feel your personal data has been mishandled. We would encourage you to contact us in the first instance but you are also entitled to complain directly to the Information Commissioner’s Office (ICO) (if you are in the UK), or to your local data protection authority (if you are outside the UK).