The aim of this document is therefore to explain how we collect, protect, use and disclose your personal data as defined under the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”), when you, in your capacity of user or website visitor access or use our website, mobile application and any other online service which is linked to our services.
What personal data do we collect and why?
It may well be the case that we will store information you may choose to send to us:
We receive and store any information that you knowingly provide to us in the following situations:
- Creation of an account on our mobile application;
- Account link with third-party services, which can include communication or any other interaction, which involves the disclosure of your data;
- Direct customer support requests via tools available on our website/mobile application. We may use the information to resolve technical issues you may encounter, analyse crash information and repair and also improve our Services.
It is important to underline that the collection of this data is necessary under the relevant applicable legislation.
Subject to your consent, we will automatically collect the following information when you use or access our Services::
- Information regarding your web browser;
- Time zone;
- Web pages viewed;
- IP address.
This collection of data aims at personalising your experience on the Site and mobile application, improve customer service and respond to queries and emails of our customers. It is important to highlight that this information will not otherwise be aggregated in such a way that would enable us to identify any particular user of the system.
Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.
We collect Device Information using the following technologies:
– “Cookies” are data files that are placed on your device or computer and often include a unique anonymous identifier. More information about the cookies we use is available here:- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
– “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site. It is important to highlight that this information will not otherwise be aggregated in such a way that would enable us to identify any particular user of the system.
Additionally, when you make a purchase or attempt to purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers email address, and phone number). We refer to this information as “Order Information”.
To make our website work properly, small data files called cookies are sometimes placed on your device.
A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over some time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
Please note that removing or blocking cookies can impact your user experience, and some functionality may no longer be available.
Subject to your consent, our mobile application may request access to your files available on your device (contacts, photos or use of the camera), which are necessary to enable certain features of the Services. It is important to highlight that this information is not automatically collected. Information related to your geolocation may also be stored for statistical purposes.
Purpose of processing your personal information
We may process personal information related to you if you have given consent for one or more specific purposes. Please note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. This, however, does not apply, whenever the processing of Personal Information is subject to European data protection law, in particular with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation); (i) Provision of information is necessary for the performance of a contract with you and/or for any pre-contractual obligations thereof or for an agreement concluded in your interest; (ii) Processing is necessary for the purpose of the legitimate interests pursued by a third party or by us; or (iii) Processing is necessary for compliance with a legal obligation to which we are subject to. In any case, we will be happy to clarify the specific legal basis that applies to the specific case of processing your personal data, and in particular whether the provision of personal data that is a statutory or a contractual requirement, or a requirement necessary to enter into a contract. As a consequence, you may contact us at the following address: email@example.com
Use of Information
It is important to highlight that together with our service providers; we may use the information we had collected in order to protect, preserve, manage and enhance our Services. This may also be applicable in relation to any competition or advertising campaign and to associate crypto asset companies with users who may show interest in investing with the latter. In order for this to be achievable, we may use your personal data when communicating with you about our Services or of third-parties. Hereunder, you may find a list of the information PlebApp is processing:
- Administer and hand over the products and services you request, process transactions and dispatch to you relevant information.
- Identify, examine and forestall dishonest or crooked transactions and any other illicit activities;
- Safeguard the rights of the PlebApp and other related parties;
- Interact with users and website visitors by treating any comments, questions or inquiries;
- Providing advertisements containing, offers, prizes or promotions about our products or relevant information;
- Following statistics Monitor and analyse trends, data and content usage and activities in relation to our Services;
- Adapt the Services and provide advertisements, content or features based on the user profiles or interests; and
- Merge the information we receive from others
to better understand and manage your needs and enhance your experience.
PlebApp is subject to the jurisdiction and applicable laws in the Netherlands. By accessing or using our Service, you consent as you acknowledge that we process data in the European Union and the USA.
Third-parties and authorities
Personal data held by us may be accessed/transferred to third parties when it is legally permitted to do so. When we will share personal data with others, this will only be accomplished under contractual arrangements and security mechanisms put in place intended to protect your personal information and to comply with our data protection, confidentiality and security standards. Such transfers may take place with:
- Other third-party organisations that provide applications functionality, data processing, IT or audit services to us. We use third-parties for support in providing the Services and to help provide, run and manage our internal IT systems, i.e. website hosting in Google cloud.
- We may have to share your personal data at the request of law enforcement or other government and regulatory agencies or to other third parties as required by law, and in accordance with, applicable law or regulations.
Social Sharing Features
It is important to highlight that we may also employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Individuals have certain rights over their personal data and data controllers are responsible to fulfilling these rights. Where PlebApp decides how and why personal data is processed, PlebApp is a controller according to Article 4(7) of the GDPR and include further information about the rights that individuals have and how to exercise it below.
Managing your personal data:
When you update information, however, we maintain a copy of the unrevised information in our records for a period of 6 months. Some information may remain in our private records after your deletion of such information from your account. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements or contracts. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced anymore after the expiration of this retention period.
Right of access:
You have the right to obtain from us confirmation as to whether or not personal data concerning you are processed, and, where that is the case, you have the right to request and get access to that personal data in accordance with applicable law. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (which is currently set for 30 days). You can do this by sending an e-mail to as at Pleb@plebapp.com
Right of rectification
You have the right to obtain from us the rectification of inaccurate personal data that was submitted to us, and you have the right to provide additional personal data to complete any incomplete personal data. You can do this by sending us an e-mail at Pleb@plebapp.com
Right to erasure
In certain cases, you have the right to obtain from us the erasure of personal data. You can do this by sending us an e-mail at Pleb@plebapp.com
Right to withdraw your consent
Where we process personal data based on consent, individuals have the right to withdraw consent at any time. We do not always process personal data based on consent (as we can also rely on another legal basis, i.e. the contractual relationship between us and the customer. Nevertheless, if the processing is based on consent, you can withdraw your consent by sending us an e-mail at Pleb@plebapp.com
Right to filing complaints
You have the right to fill complaints with the applicable data protection authority on our processing of your personal information.
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
Additionally, if you are a European resident we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe and the European Economic Area (EEA), including to Canada and the United States.
How to exercise your rights?
Any requests to exercise the rights mentioned above can be directed to us through the contact details provided in this document: Pleb@plebapp.com
These requests can be exercised free of charge, and you will be informed by us as early as possible and always within one month from the date of your request. Nevertheless, where requests from data subjects are manifestly unfounded or excessive, in particular, because of their repetitive character, we may either (i) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking action requested; or (ii) refuse to act on the request.
PlebApp takes the security of all data it holds very seriously. PlebApp has a framework of policies, procedures and training in place covering professional secrecy, data protection, confidentiality and security and regular review of the appropriateness of the measures it has in place to keep the data secure.
PlebApp may update or modify the security measures periodically provided that such updates and modifications do not result in the degradation of the overall security of the services.
Marketing and promotion
We offer the possibility to all of our users to sign up for getting marketing and promotional offers, either via e-mail or via mobile push notifications.. Should you not be willing to receive such offers, you have the possibility to opt-out. Each e-mail containing promotions and offers will also contain instructions on how to opt-out. In case of mobile notifications, the possibility to disable these messages is available in the settings of your device.
It goes without saying that should you opt-out from promotional e-mails, you will also receive an e-mail containing relevant information related to your account.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We acknowledge that transparency is an ongoing responsibility, so this privacy statement will be kept under regular review.
We reserve the right to modify this Policy at any time, effective upon posting of an updated version of this policy and notified by a notification, e-mail or any other available tool.
Continued use of the Services after any such changes shall constitute your consent to such changes.
We hope that this Privacy Statement helps you understand and feel more confident about the way we process your data.
If you have any further queries about this Privacy Statement or any query about your rights protected by the relevant legislation, please contact us at the following address: Pleb@plebapp.com