Legal and Privacy

PRIVACY POLICY


This Privacy Policy constitutes a part of CREDITS Terms and Conditions (hereinafter -T&Cs). The terms used in this Privacy Policy shall have the same meanings as in the T&Cs except as otherwise specified. The terms “we”, “us” and “our” refer to CREDITS. When we ask for your personal information, it is because we are required by applicable laws or regulations to collect such information or it is relevant for our specified purposes.

This Privacy Policy has incorporated elements from the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”)) and the UK GDPR as we act in accordance with their personal information processing rules. We use standard contract clauses, rely on the European Commission’s adequacy decision about certain countries, and when applicable, conduct data protection impact assessment prior to processing which may potentially result in a high risk to your rights and freedoms and obtain your consent for these data transfers to third countries if required by applicable laws.

This Privacy Policy explains how we use the personal data we collect from you when you use our Services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY ALL THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS AND CONDITIONS. IF YOU DO NOT AGREE TO SUCH TERMS, EXIT THIS PAGE AND DO NOT ACCESS OR USE OUR SERVICES.

What data do we collect?

CREDITS collects the following dаta:

  • Personal identification information (name, home address, passport details, date of birth, email address, phone number, username, signature). This information helps us to identify you.

  • Information required by regulatory authorities (e.g. AML/CTF & KYC requirements) (identity documents, personal photo, information about the ultimate beneficiaries, proof of address, utility bills or bank statements, source of fund declaration, purposes of fund documents and source of wealth). 

  • Information related to usage of our Services (web requests, IP address, browser type, language, time zone settings, browser plug-in types and versions, operating system and hardware setting, phone number, information derived from network operator, GPS, base station and WLAN). This information helps our systems to ensure that our Services are accessible for Users across all platforms and can aid during criminal investigations. Your location information (determined through GPS and IP address) helps us to prevent fraud when your location and device type are different from what you would normally use. 

  • Information related to Transactions (account numbers, account balances, Transactions history, transaction activity, distribution history). We collect this information to monitor suspicious trading activity for fraud protection, legal case resolution and other purposes disclosed in this Policy.

  • Communication information (communication that you send to us or generated through your use of our Services, including all messages, requests or other information you send in the course of your contract with us, all communications and file attachments in connection with your usage of our Services).

How do we collect your data?

You directly provide CREDITS with most of the data we collect. We collect data and process data when you:

  • Register for, log in or visit our Website, Platform, or use any Service of CREDITS;

  • Voluntarily complete any User survey or provide feedback to us via email or other channels;

  • Use or view our Website or Platform via your browser’s or software’s cookies.

We may also receive your data indirectly from the following sources:

  • Public databases, credit bureaus and ID verification or AML/KYC verification partners and transaction monitoring tools;

  • Third parties that provide services to you or us;

  • Blockchain data;

  • Marketing partners and resellers;

  • Advertising partners and analytics providers.

How will we use your data?

We collect your data so that we can:

  • Provide and maintain CREDITS Services. We use the collected information to deliver, maintain and improve CREDITS Services and verify our Users’ identities. 

  • Protect our Users. We use the collected information to protect our Website, Platform, Users’s Accounts and archives. We use IP addresses and cookies to protect against automated abuse such as spam, phishing and other hacker attacks. 

  • Comply with legal and regulatory requirements. We use the information in compliance with our legal obligations and government requests. In cases where it is strictly necessary to fulfill the purpose of public interest, to pursue our reasonable interests (without causing damage to the interests of our Users), we may process your personal information without your consent. We will not disclose or provide any of your personal information to third parties without a review from our legal team and/or your prior consent, except for the situations stated in this Privacy Policy or our T&Cs.

  • Communicate with you. We use your personal information like your phone number or email address to interact with you directly when providing customer service or to keep you informed on logins, transactions, account security and other aspects. All direct communications are properly kept at CREDITS or the service provider designated by CREDITS, to be reviewed for accuracy, to be kept as evidence, or to be used to perform other statutory or contractual obligations.

  • Enforce our T&Cs and other agreements with our Users. It includes, but not limited to reviewing, investigating, and preventing any potentially prohibited or illegal activities that may violate the foregoing provisions, or disclose the relevant information to a third party in accordance therewith.

  • Marketing and advertising. We may use your personal information for the purposes of targeting, modeling, and/or analytics as well as marketing and advertising.

  • Establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

Please do not supply any other person’s personal data to us, unless we prompt you to do so and/or we have agreed in writing prior to receiving the data from you. Any information that we receive that is not identified shall be notified to you and destroyed immediately.

Transfer of your personal data 

You understand that we have the right to have all or some of the collected personal information transferred to or stored in other countries or regions than your country of nationality, your country of residence, or the country where the server is, without your specific consent, under the following circumstances:

  • If it is necessary to protect, process, analyze, reasonably use the personal information;

  • If it is necessary to enforce our T&Cs and other agreements with our Users;

  • If it is necessary for the public interest;

  • If it is necessary to establish, exercise or defend the rights of us, our partners, or other Users;

  • Other circumstances required by law or government orders.

We share your data with our partner companies or contractors to be able to provide you with Services. For example, your Transactions may be handled by external payment service providers.We may disclose your data to one or more of those selected payment services providers via APIs and/or other methods of integration to enable them to connect your Account with their services. Each such payment services provider will act as a data controller in relation to the data that we supply to it and can provide you a copy of its own privacy policy, which will govern that third party’s use of your personal data. 

Some of our Services or activities may be outsourced to third parties which will process your personal data (e.g. third party organizations that provide applications/functionality, data processing or IT services to us). We will share your personal data only to the extent necessary for the purposes defined in the relevant agreements.  We use standard contract clauses, rely on the European Commission’s adequacy decision about certain countries, and when applicable, conduct data protection impact assessment prior to processing which may potentially result in a high risk to your rights and freedoms. By using our Services you give us your consent to process your personal data in third countries, including outside the EEA or the UK. You have the right to obtain copies of the standard contractual clauses, a summary description of the security measures we put in place for your personal data processing in third countries and a list of subcontractors used for your personal data processing. Please send your request to info@credits.com and we will provide you with this information within one month. You also have the right to revoke your consent at any time by sending us an email to info@credits.com.

How do we store and protect your data?

We take all necessary precautions to safeguard the privacy of your personal information. We use technical, contractual, administrative and physical security steps to protect your personal information. We adopted security measures such as restricted access, scanning, encryption, firewall to minimize the risk that your information may be lost, disclosed, misused, accessed without authorization, disclosed without authorization, or altered. 

Please be aware that no data transmission over the Internet or via email is completely secure and therefore we cannot guarantee the protection of all personal information in all cases. As such, we request that you understand the responsibility to independently take safety precautions to protect your own personal information. You agree that we shall not be liable for any information leakage and other losses caused by force majeure and/or intentional acts of third parties, including but not limited to hacker attack, power interruption, or unavoidable technical failure, to the maximum extent permitted by Law.

Also, please remember that materials posted to online forums such as bulletin boards or chat rooms are public, not secure, and may be viewed by anyone. Any personal information you post may be collected and used by anyone and may result in unsolicited messages from other parties.

Marketing

We like to send you information about products and services of ours that we think you might like. If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please click on the unsubscribe link in the bottom of the marketing email and submit your request to unsubscribe.

What are your data protection rights?

We would like to make sure you are fully aware of all of your data protection rights. Every client is entitled to the following:

  • The right to access – You have the right to request us for copies of your personal data. We may charge you a reasonable fee for providing this service.

  • The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete within a reasonable limit.

  • The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

  • The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions. However, you should understand that such restriction of the processing may prevent us from providing you with some of CREDITS Services.

  • The right to object to processing – You have the right to object that we process your personal data, under certain conditions. However, you should understand that such restriction of the processing may prevent us from providing you with some of CREDITS Services.

  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. We may charge a reasonable fee for providing this service.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: info@credits.com.

What About Cookies and Other Identifiers?

We use cookies and similar tools to enhance your user experience, provide our services, and understand how customers use our services so we can make improvements. To enable our systems to recognize your browser or device and to provide our services to you, we use cookies.

We use operational cookies and similar tools (collectively, "cookies") to provide our services, including:

  1. Recognizing you when you sign in to use our services.

  2. Providing customized features and services.

  3. Displaying features and services that might be of interest to you, including ads on our services.

  4. Preventing fraudulent activity.

  5. Improving security.

  6. Keeping track of your preferences, such as currency and language.

We also use cookies to understand how users use our services so we can make improvements.

You can manage your cookie preferences through your browser settings. The settings on your browser will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable and remove cookies, and when cookies will expire.

Operational cookies allow you to take advantage of some of our essential features. If you block or otherwise reject operational cookies through your browser settings, some features and services may not work.

Cookies Classification:

By duration:

  1. Session cookies: Session cookies are stored in a temporary storage location and expire once you leave the site or close the browser. The cookies and associated data are deleted at the end of the browsing session.

  2. Persistent cookies: Persistent or permanent cookie files remain stored on your computer or device until they are deleted or reach their expiration date. Each cookie has a different lifespan.

By purpose:

  1. Necessary cookies: These cookies are essential for the website's navigation, performance, security, and functionality. They are required to deliver information and services to you. Necessary cookies, such as those used to display content and allow you to log in to your account, do not require consent.

  2. Preference cookies: Preference cookies, also known as "customized cookies," allow our site to remember your preferences, helping you customize your experience. For example, they remember you when you return to our website, direct you to the homepage of your current location, and provide live chat support if needed.

  3. Statistical cookies: Statistical cookies, also known as "performance improvers," help us understand how you use and interact with the website, allowing us to make improvements. They collect aggregated data and do not use personal data. For example, these cookies gather information about visitors' website usage patterns and help identify recurring errors. This allows us to provide necessary information and update the website according to user interests.

  4. Marketing cookies: Marketing cookies, also known as "targeters" or "advertising cookies," are used to deliver targeted content based on behavioral traits and measure the success of our marketing campaigns. These cookies may remember your web browsing activity and actions across websites, as well as analyze demographic information. They enable us to advertise our services to potential customers after they leave our website, serving them ads on other sites they visit later.

Please note that we anonymize data collected through statistical cookies, ensure data sharing is turned off, and do not use other Google services in combination with Google Analytics cookies unless you have provided consent for the use of marketing cookies.

If you have any further questions or wish to receive a list of cookies we use and/or revoke the use of cookies under applicable data protection laws, please contact us at info@credits.com.

Privacy policies of other websites

Our Privacy Policy applies only to our Services. If you visit other third-party platforms or partner’s websites, apps via the links on CREDITS, you should agree with and abide by their separate and independent privacy policies. We are not responsible for the content or the activities therein, you should read their privacy policy.

Changes to our Privacy Policy

We keep our Privacy Policy under regular review and place any updates on this web page. You shall regularly review the Privacy Policy and pay attention to its revisions. If you do not agree with the revised content, you shall stop accessing CREDITS immediately. When an updated version of the Privacy Policy is released, your continued access to CREDITS means that you agree to the updated content and agree to abide by the updated Privacy Policy.

How to contact us?

If you have any questions about our Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: info@credits.com 

How to contact the appropriate authority?

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact your National Data Protection Authority if you are a resident of the EEA, or the Information Commissioner’s Office in the UK. Residents of other jurisdictions may contact their national data protection authority.