Gleec Privacy Policy
Welcome to Gleec
Privacy Policy (the Policy).
The Gleec
website and Gleec mobile apps are owned by the
company Gleec-BTC OÜ, incorporated in the Republic of
Estonia, with company number 14477970, registered office at Tornimäe
5, 2nd floor 10145 Tallinn, which is regulated by the laws of that country (the
Gleec).
As a high-level summary, we are
an evolving cryptocurrency-focused financial institution providing various
cryptocurrency-related financial services (the Services). We
provide all this by means of the website www.gleec.com (the Website)
and the related applications and crypto-platforms that we may operate from time
to time (each of which, is a Platform) and which may be
accessible via the Website or otherwise.
Accordingly, the purpose of this
Policy is to set out the basis on which we will process your Personal data when
you:
This also includes any data which
you may provide to us for our events, newsletters, and other marketing items.
This Policy informs you about the
items of Personal data that we may collect about you and how we will handle it,
and in turn, also tells you about
Please read the following
information carefully to understand our practices regarding your Personal data.
General Data Protection
Regulation (Regulation (EU) 2016/679) (GDPR) regulations shall be implemented
for EU users (the Regulation or the GDPR).
This Policy aims to ensure that
you are fully informed on how we will collect and process your Personal data in
the circumstances and scenarios outlined in the Introduction (namely,
through your token subscriptions and purchases, your use of the Website, and
any of the related Services).
The Websites, the
Platform, and the Services are not intended or in any way made available
for minors, and we do not knowingly collect data relating to minors.
It is important that you read
this Policy together with any other privacy or fair processing notice we may
provide on specific occasions when we are collecting or processing Personal
data about you so that you are fully aware of how and why we are using your
data. This Policy supplements the other notices and is not intended to override
them.
The opening and registration of a
customer account will give rise to the existence of a contractual relationship
with us, as regulated by our Terms of Use, and all matters between you and us
relating to Services will be deemed to fall within the subject matter of that
same contractual relationship. Furthermore, the existence of this contract
between you and us will also serve as the legal basis for a number of our processing
activities involving your Personal data, as detailed below.
Controllers
Gleec (as defined) above is the controller and is
responsible for your Personal data. There may be other controllers of
your Personal data, such as, for example, electronic identification
verification service providers, or Associated companies or other service
providers engaged by us for purposes of processing and storing your Personal
data. They will be so-called joint controllers of your Personal data and as
such, will share responsibility for such control with us.
Presently, we use the services of
the following service providers:
Sum & Substance: https://sumsub.com for KYC/AML verification;
Safened:
https://www.safened.com for KYC/AML verification;
Ondato: https://www.ondato.com for KYC/AML verification;
Connectum:
https://www.connectum.com for credit and debit card processing and
acquiring;
EmailOctopus: https://emailoctopus.com for handling e-mail lists and campaigns;
and
HasOffers: https://www.hasoffers.com for performance marketing.
Please familiarize yourself with
these providers and their privacy and liability policies. If you find any of
these may not work for you, please do not access any of the Websites and do not
use any of our Services.
As a general rule, we always seek
to minimize the amount of your Personal data that we ourselves collect and store.
Contact details
Full name of legal entity: Gleec-BTC OÜ
Email address: support@gleec.com
Please use the words Data
Protection Matter in the subject line.
Changes to the Policy and
your duty to inform us of changes
This version was last updated on
the 8th of June 2023.
It is imperative that the Personal data we hold about you is accurate and current at
all times. Otherwise, this will impair our ability to process your token purchases
and/or our ability to provide you with the Services that you may request from
us (amongst other salient issues).
Please keep us informed if any of
your Personal data changes during your relationship with us.
Third-party links
Our Website
may include links to third-party websites, plug-ins and applications. Clicking
on those links or enabling those connections may allow third parties to collect
or share data about you. We do not control these third-party websites and are
not responsible for their privacy notice or policies. We strongly encourage you
to read the privacy notice of every website you visit, particularly when
leaving our Website.
Set out below are key definitions
of certain data protection terms which appear in this Policy.
Consent Form refers to separate documents which we
might from time to time provide you where we ask for your explicit consent for
any processing which is not for purposes set out in this Policy.
Data subjects means living individuals (i.e. natural persons) about whom we collect
and process Personal data.
Data controller or controller means any
entity or individual who determines the purposes for which, and the manner in
which, any Personal data is processed.
Data processor or processor means any
entity or individual that processes data on our behalf and on our instructions
(we being the data controller).
Personal data means data relating to a living
individual (i.e. natural person) who
can be identified from the data (information) we hold or possess. This
includes, but is not limited to, your name and surname (including maiden name
where applicable), address, date of birth, nationality, gender, civil status,
tax status, identity card number & passport number, contact details
(including mobile and home phone number and personal email address),
photographic image, bank account details, emergency contact information as well
as online identifiers. The term personal information, where
and when used in this Policy, shall have taken the same meaning as Personal
data.
Processing means any activity that involves use of
Personal data. It includes obtaining, recording or holding the data, or
carrying out any operation or set of operations on the data including,
organizing, amending, retrieving, using, disclosing, erasing or destroying it.
Processing also includes transferring Personal data to third parties.
Sensitive Personal data, sensitive data or special
categories of Personal data includes information about a person's
racial or ethnic origin, political opinions, religious or similar beliefs,
trade union membership, physical or mental health or condition or sexual life,
or about the commission of, or proceedings for, any offence committed or
alleged to have been committed by that person, the disposal of such proceedings
or the sentence of any court in such proceedings. This type of sensitive data
can only be processed under strict conditions.
Note that Personal data
does not include information relating to a legal person (such as, for example,
a company). Therefore, information such as a company name, its company number,
registered address and VAT number, does not amount to Personal data in terms of
both the Act and the GDPR. Naturally, we will still treat any and all such
information in a confidential and secure manner.
Personal data, or personal
information, means any information about an individual from which that person
can be identified. It does not include data where the identity has been removed
(anonymous data).
We may collect, use, store, share
and disclose different kinds of Personal data about you which (for
purely indicative purposes) we have grouped together as follows. For
the avoidance of doubt, categories marked in blue are not applicable to
non-customers (i.e. individuals who do not hold a
registered customer account with us).
We will also collect, use and
process any other information that you voluntarily choose to provide or
disclose to us where relevant for processing your token requests and/or
providing you with your requested Services. Any such information that we
receive from you would fall under the Transaction Data
category.
We also collect, use and share
Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your Personal data but is not considered
Personal data in law as this data does not directly or indirectly reveal your
identity. For example, we may aggregate your Website Visit Data to calculate the
percentage of users accessing a specific feature of the Website. However, if we
combine or connect Aggregated Data with your Personal data so that it can
directly or indirectly identify you, we treat the combined data as Personal
data which will be used in accordance with this Policy.
·
If you fail to provide Personal data
Where
we need to collect Personal data about you:
and you either fail to provide that data when requested, or else provide
incomplete or insufficient data, we may not be able to perform or conclude the contract which we have or
are otherwise trying to enter into with you (namely regarding your account
opening, token subscriptions and purchases, and provision of the Services).
In
certain cases, particularly where it relates to KYC due diligence data (both
standard and enhanced), we may even need to exercise our prerogative to
terminate our contract with you in accordance with the terms thereof, or else,
if still at the application stage, we may have to decline to enter into a
customer relationship with you.
We
will however notify you if this is the case at the time.
Special categories of Personal data
We do not knowingly collect Special Categories of Personal data (or
Sensitive Personal data) about you. Should we receive sensitive Personal data about
you, we will only process that data when there is a legitimate basis to do so
and, in all circumstances, in accordance with our obligations at law and under
the appropriate safeguards.
As set
out below in Section 5, we collect and process AML and
KYC Data and, if applicable, Enhanced KYC Data in
order to order to (i) conduct our AML and KYC checks,
and other due diligence checks, on you, (ii) verify your identity or claimed
identity and, in those instance of enhanced due diligence, your source of funds
and source of wealth, (iii) take an informed decision on whether we want to
enter into a customer relationship with you, and, if positive, to conduct
initial and ongoing screening and monitoring and (iv) to comply with any legal
or regulatory obligation that we may have and/or any Court, regulatory or
enforcement order that may be issued upon us.
We
generally use different methods to collect data from and about you including
through:
Account Registration. We will ask you to provide us with your Identity, Contact and AML and Risk
Data when you apply to open a customer account with us. You provide this
information, which will then be collected and processed, when you fill in and
submit your account application form (together with other related forms) and
complete the required application steps.
Direct Interactions. You may give us your Identity, Contact and AML and Risk Data, Enhanced
KYC Data and Marketing and Communications Data by filling on our forms (such as
our Contact Form accessible at www.gleec.com completing our token pre-sale documentation or by
corresponding with us by post, phone, email or otherwise. This includes
Personal data you provide when you:
Through our provision of
the Services. This
may encompass all of the data categories listed in Section 3 (namely, Identity,
Contact, AML and Risk Data, Enhanced KYC Data and Transaction Data).
Automated technologies or
interactions. When
you interact with our Website, we may automatically
collect Technical and Usage Data about your equipment, browsing actions and
patterns. We may collect this Personal data by using cookies, server logs and
other similar technologies.
Please see our Cookie Policy for further details.
Third parties or publicly
available sources. We
may receive Personal data about you from various third parties and public
sources as set out below:
Technical Data from the following
parties:
Identity, Contact, AML and Risk
Data and Enhanced KYC Data from publicly available sources such as public court
documents, the RoC and the company houses and
registers of other jurisdictions, and from electronic data searches, online KYC
search tools (which may be subscription or license based), anti-fraud databases
and other third party databases, sanctions lists,
outsourced third-party KYC providers and from general searches carried out via
online search engines (e.g. Google).
If you attend an event or meeting
at our offices, we may hold images of you captured by our CCTV cameras.
We may also receive customer due
diligence reports about our applicants from our outsourced third-party KYC
provider. These reports may encompass identity checks, document integrity
checks, checks against global sanctions lists and related screening and
monitoring measures. In such cases, this third-party provider will conduct the
requested customer due diligence checks in an autonomous manner and
will generally amount to a controller of the Personal
data which it collects in connection with those checks. It also has its own
data policies and practices, which will be duly notified and communicated to
the applicant.
We will only use your Personal
data when the law allows us to. Most commonly, we will use your Personal data
in the following circumstances:
Where you wish to enter into a
customer relationship with us.
Where we need to perform the contract we have or which are about to enter into with you
as a customer (including in respect of your token purchases and subscriptions,
and use of the Services).
Where it is necessary for our
legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests.
Where we need to comply with a
legal or regulatory obligation.
You have the right to withdraw
consent to such marketing at any time by contacting us, as indicated above
under Contact Details.
Purposes for which we
will use your Personal data
We have set out below, in a table
format, a description of all the ways we plan to use your Personal data, and
which of the legal bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate.
Note that we may process your
Personal data pursuant to more than one lawful ground or basis, depending on
the specific purpose for which we are using your data. Please contact us at support@gleec.com if you need details about the specific
lawful basis we are relying on to process your
Personal data where more than one lawful basis has been set out in the table
below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
(a) To conduct customer due diligence measures on you (following your application to enter into a customer relationship with us). (b) To determine whether we want to enter into a customer relationship with you and, if positive, to register your customer account and on-board you as a customer. |
(a) Identity; (b) Contact; (c) AML and KYC. |
(a) Performance of a contract with you or in order to take steps at your request prior to entering into such a contract. (b) Necessary for our legitimate interests (to verify your identity, conduct initial screening and monitoring (sanctions lists, fraud databases and other KYC checks), determine whether you present any risks as a prospective customer, and ultimately to enable us to take an informed decision on whether we want to enter into a customer relationship with you). |
|
(a) To establish and verify your identity. (b) To fulfill our other internal KYC policies and requirements. |
(a) Identity; (b) Contact; (c) AML and KYC; (d) Enhanced KYC Data (for payments over a certain threshold); and (e) Transaction. |
Necessary for our legitimate interests (for risk assessment purposes, to prevent and mitigate against fraud, to safeguard the reputation of our business). |
|
(a) To enable your use of the Platform, process your token subscriptions, purchases and trading activity, and provide you with the Services that you have requested from us. (b) To keep your account portfolio accurate and updated. (c) Manage transactions and generate transaction reports and records. |
(a) Identity; (b) Contact; (c) Financial; (d) Transaction; and (e) Portfolio. |
(a) Performance of a contract with you. (b) Necessary to comply with our contractual obligations. (c) Necessary to comply with a legal obligation. |
|
For tax and accounting purposes (e.g. reporting to tax authorities, and accounting and reporting requirements). |
(a) Identity; (b) Contact; (c) Financial; and (d) Transaction. |
Necessary to comply with a legal obligation. |
|
(a) For billing and invoice purposes; (b) To collect and recover money which is owed to us (debt recovery); (c) Internal record keeping (including files). |
(a) Identity; (b) Contact; (c) Financial; (d) Transaction; and (e) Portfolio. |
(a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to recover debts due to us, to keep track of your token subscriptions and purchases and the provision of the Services to you (including any developments that took place), and to then be able to review such information should an issue arise). |
|
To manage our customer relationship with you, which may include to: (a) notify you about changes to our terms of service or privacy notices; (b) set up, manage and administer your customer account on the Website; (c) distribute and account your funds; (d) deal with your enquiries, requests, complaints or reported issues; (e) contact you in the course of providing the requested services; (f) ask you to participate in a survey; (g) request feedback from you; (h) advise you of industry and legislative updates, (i) inform you about our events and seminars (including webinars); (j) provide you with information about our products and services; (k) provide you with any other information or materials which you have requested from us. |
(a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Usage; (f) Portfolio; and (g) Marketing and Communications. |
(a) Performance of a contract with you. (b) Necessary for our legitimate interests (for customer relationship handling and management, to study business growth and possible trends regarding our products and service areas, to enable a review and assessment of our products and service provision, to develop and grow our business). |
|
(a) To detect, prevent and/or report fraud or any other potentially illegal or prohibited activity that comes to our attention. (b) To assist and cooperate in any criminal or regulatory investigations against you, as may be required of us. (c) To enforce our service terms. (d) To protect the rights and property of ourselves and others. |
(a) Identity; (b) Contact; (c) AML and KYC; (d) Enhanced KYC; (e) Data; (f) Financial; (g) Transaction; and (h) Payment. |
(a) Necessary to comply with a legal obligation. (b) Necessary for our legitimate interests (including, to protect the reputation of our business). |
|
To administer and protect our business, the Website and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
(a) Identity; (b) Contact; (c) Usage; (d) Technical; and (e) Website Visit. |
(a) Necessary for our legitimate interests (for running and administering our business (including IT support), systems administration, network security, to prevent fraud and to maintain the confidentiality of communications, and in the context of a business reorganization or group restructuring exercise). (b) Necessary to comply with a legal obligation. |
|
(a) To carry out market research campaigns; (b) To market our products and services to you by email or other means if you have subscribed to one of our mailing lists (where you are not a customer); (c) To deliver relevant Website content and advertisements to you, and measure or understand the effectiveness of the advertising that we serve to you. |
(a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Website Visit; and (f) Marketing and Communications. |
(a) Necessary for our legitimate interests (to develop our products and services and grow our business, to define our customers, to keep our products, services and the Website updated and relevant, and to inform our marketing strategy). (b) On the basis of your consent, in the absence of a customer relationship. |
|
To permit us to pursue available remedies or limit any damages which we may sustain. |
(a) Identity; (b) Contact; (c) AML and KYC; (d) Enhanced KYC; (e) Data; (f) Financial; (g) Transaction; (h) Portfolio; and (i) Marketing and Communications. |
(a) Performance of a contract with you. (b) Necessary for our legitimate interests. |
Legitimate Interest means our interest to conduct and manage
our business affairs appropriately and responsibly, to protect the reputation
of our business, and to provide our customers with the best possible service
and the users of the Websites with a secure experience. We make sure we
consider and balance any potential impact on you (both positive and negative)
and your rights before your Personal data is processed for our legitimate
interests. We do not use your Personal data for activities where our interests
are overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law). You can obtain further information
about how we assess our legitimate interests against any potential impact on
you in respect of specific activities by contacting us at the following email
address: support@gleec.com
Performance of Contract means processing your data where it is
necessary for the performance of a contract to which you are a party or to take
steps at your request before entering into such a contract. This includes our
Terms of Service or other applicable terms of business.
Comply with a legal
obligation means
processing your Personal data where it is necessary for compliance with a legal
or regulatory obligation to which we are subject.
Marketing
We strive to provide you with
choices regarding certain Personal data uses, particularly around advertising
and marketing. Through your Identity, Contact, Usage, Technical and Website
Visit Data, we are able to form a view on what we think you may want or need.
This is how we then decide which of our products and/or services may be
relevant or of interest to you (our marketing communications).
You may receive marketing
communications from us (which may consist of newsletters, industry and
legislative updates, mailshots, publications and/or information about our
events, seminars and webinars) where:
Where the above does not
apply to you, we
will only send you our marketing communications if you have expressly consented
to receive them from us.
Third-Party Marketing
We will get your express opt-in
consent before we share your Personal data with any third parties (including
our affiliated entities) for marketing purposes.
Opting out
You can ask us to stop sending
you marketing communications (unsubscribe) at any time by following the opt-out
(unsubscribe) links on any marketing communication sent to you.
Cookies
You can set your browser to
refuse all or some browser cookies, or to alert you when the Website sets or
accesses cookies. If you disable or refuse cookies, please note that some parts
of the Website may become inaccessible or not function properly. This Policy
should be read in conjunction with our Cookie Policy.
Change of purpose
We will only use your Personal
data for the purposes for which we collected it, unless we reasonably consider
that we need to use it for another reason and that reason is compatible with
the original purpose, or we are obliged to process your data by applicable laws
or court / enforceable orders.
If you wish to get an explanation
as to how the processing for the new purpose is compatible with the original
purpose, please contact us at support@gleec.com
If we need to use your Personal
data for an unrelated purpose, we will notify you and we will explain the legal
basis which allows us to do so. Please note that we may process your Personal
data without the need to obtain your consent, in compliance with the above
rules, where this is required or permitted by law.
We may have to grant access to,
disclose or share your Personal data with the parties set out below (which may
be in or outside your jurisdiction) for the purposes set out in the table in Clause
5 above:
We require all affiliated
entities and third-party service providers to respect the security of your
Personal data and to treat it in accordance with the law. We do not allow them
to use your Personal data for their own purposes and only permit them to
process your Personal data for specified purposes and in accordance with our
documented instructions. Our service providers currently store your Personal
data in Germany. We will update this Privacy Policy if their data storage
location changes.
We do not generally transfer your
Personal data to outside the European Economic Area (EEA)
except
as may be necessary to: (i) process your transactions, subscriptions, purchases,
and/or trading activity, (ii) provide the requested services, (iii) fulfill our
contractual obligations to you, (iv) exercise and enforce our contractual
rights and terms of services, (v) comply with our legal and/or regulatory
obligations or (vi) assert, file or exercise a legal claim.
Where we do need to transfer your
Personal data to outside the EEA (whether for these stated purposes or any
other purpose listed in Clause 5 above), we will ensure a
similar degree of protection is afforded to that Personal data by ensuring at
least one of the following safeguards applies or is otherwise implemented:
Please contact us at support@gleec.com if you want further information on the specific
mechanism used by us when transferring your Personal data out of the EEA.
We have put in place appropriate
security measures to prevent your Personal data from being accidentally lost,
used or accessed in an unauthorized way, altered or disclosed (i.e. to safeguard its integrity and confidentiality). We
also regularly review and, where practicable, improve upon these security
measures.
We also limit access to your
Personal data to strictly those employees, agents, contractors, and third
parties that have a professional need-to-know. They will only process your
Personal data on our instructions and they are subject to a duty of
confidentiality. All our employees and agents have received appropriate
training on data protection.
We have put in place procedures
to deal with any suspected Personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.
Please note that we
consider our relationship with customers to be an ongoing and continuous
customer relationship, until such time that either we or the customer
terminates it in accordance with our Terms of Use.
We will only retain your Personal
data for as long as necessary to fulfill the purposes for which we collected it
(see Section 5 above) and, thereafter:
By and large, our retention of
your Personal data shall not exceed the period of six (6) years from
the termination of your customer relationship with us (which would typically
arise from the closure or termination of your customer account). This retention
period enables us to make use of your Personal data for any applicable AML
retention and reporting obligations and for the filing, exercise or defense of
possible future legal claims (taking into account applicable prescriptive
periods and statutes of limitation). In certain cases, we may need to retain
your Personal data for a period of up to ten (10) years in order
to comply with applicable accounting and tax laws (this will primarily consist
of your Transaction Data). There may also be instances where the need to retain
Personal Data for longer periods, as dictated by the nature of the products and
services provided.
In some circumstances, you can
ask us to delete your data. See Request erasure below for
further information.
Kindly contact us at support@gleec.com for further details about the retention periods
that we apply.
Data Minimization
To the extent possible, we may
anonymize the data which we hold about you when it is no longer necessary to
identify you from the data which we hold about you. In some circumstances, we
may even pseudonymize your Personal data (so that it can no longer be
associated with you) for research or statistical purposes, in which case we may
use this information indefinitely without further notice to you.
Under certain circumstances, you
have rights under data protection laws in relation to your Personal data.
Please click on the links below to find out more about these rights:
If you wish to exercise any of
the rights set out above, please contact us at support@gleec.com
No fee is usually charged
You will not have to pay a fee to
access your Personal data (or to exercise any of the other rights). However, we
may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may simply refuse to comply with your request in
such circumstances.
What we may need from you
We may need to request specific
information from you to help us confirm your identity and ensure your right to
access your Personal data (or to exercise any of your other rights). This is a
security measure to ensure that Personal data is not disclosed to any person
who has no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all
legitimate requests within a period of one month from the date of receiving
your request. Occasionally it may take us longer than a month if your request
is particularly complex or you have made a number of requests. In this case, we
will notify you and keep you updated.
You have the right to:
You may send an email to support@gleec.com requesting information as the Personal
data which we process. You shall receive one copy free of charge via email of
the Personal data which is undergoing processing. Any
further copies of the information processed shall incur a charge of €10.00.
Note, however, that we may not
always be able to comply with your request of erasure for specific legal
reasons which will be notified to you, if applicable, at the time of your
request. These may include instances where the retention of your Personal data
is necessary to:
In some cases, we may demonstrate
that we have compelling legitimate grounds to process your personal information
that override your rights and freedoms.
Kindly note that none of
these data subject rights are absolute, and must generally be weighed against
our own legal obligations and legitimate interests. If a decision is taken to
override your data subject request, you will be informed of this by our data
protection team along with the reasons for our decision.
Complaints
You have the right to lodge a
complaint at any time to a competent supervisory authority on data protection
matters, such as (in particular) the supervisory authority in the place of your
habitual residence or your place of work.
We would, however, appreciate the
opportunity to deal with your concerns before you approach the supervisory
authority, so please contact us in the first instance at support@gleec.com
We reserve the right to make
changes to this Policy in the future, which will be duly notified to you. If
you have any questions regarding this Policy, or if you would like to send us
your comments, please contact us today or alternatively write to our data
protection team using the details indicated in this Policy.