Coinwink

Privacy Policy

Last updated: November 10, 2023

This Privacy Policy ("Policy") sets out the terms and conditions regarding the collection, use and disclosure of Personal Data received from users of the cryptocurrency price alerts, watchlist and portfolio tracking web-app (the "App").

The controller of Personal Data

UAB Pictoproof is the data controller in respect of all Personal Data collected and used by Coinwink ("We" or "Us").

We are registered at Olandu Street 53-36, Vilnius, Lithuania. You can contact us by e-mail moc.kniwnioc@ofni.

Personal Data collected and used by us

Personal Data is information that identifies an individual. We collect and use Personal Data from App users, such as their e-mail address and phone number ("User Data"), cookies and information that your browser sends whenever you visit our App ("Log Data").

Purpose and legal basis for processing Personal Data

We process Personal Data for the following purposes and under the following legal grounds under the General Data Protection Regulation ("GDPR"):

to verify the user for registration and accessing Coinwink’s account – we use User Data to verify user’s identity and to manage your account registration. For the App to be more user-friendly, we also collect the last e-mail address and phone number used with the account, and later pre-fill this information in the New Alert creation form. The processing of this data is necessary to fulfil the terms regulating the use of the App (Article 6 (1) (b) of the GDPR);
to alert you about your tracked crypto holdings and favourites from different blockchains – in order to properly provide these services, we use User Data. In these activities we rely on your consent (Article) 6 (1) (a) of the GDPR). Please note that our cryptocurrency exchange rate alerts sent to you as email or SMS messages are considered to be service messages and do not contain any direct marketing material;
to provide user behaviour insights and statistics for our App – we collect Log Data, that may include information such as your device Internet Protocol ("IP") address, browser type, browser version, the pages of our App that you visit, the time and date of your visit, the time spent on those pages and other statistics. This information is used in order to provide user behaviour insights and statistics for our App. In these activities we rely on our legitimate interest to improve our services and user experience (Article 6 (1) (f) of the GDPR);
to record logs of communication alerts delivered to the user – starting from 2019, we record logs of all delivered e-mail, SMS and Portfolio alerts. Every user can view his or her alerts history under "Manage Alerts" section. In these activities we rely on our legitimate interest to provide the best user experience (Article) 6 (1) (f) of the GDPR);
for processing your payment data – Stripe is directly responsible for processing your payment data. When processing your payment, we never observe your credit or debit card details, as they are only collected by the Stripe service. For more details, please refer to the Stripe privacy policy. The processing of this data is necessary for the performance of a contract (Article 6 (1) (b) of the GDPR).

Data retention period

You can permanently delete your account anytime. Once you delete your account, all the resources and data associated with you as a user are automatically deleted from our database. Financial records are retained for 10 years after the purchase transaction.

Account inactivity

If your Coinwink account remains inactive for more than 2 years, we reserve the right to permanently delete your account and all data associated with it. Prior to any deletion, we will make reasonable efforts to notify you through the contact information provided during registration.

Security

Coinwink is a privacy-focused service. When processing and storing your personal data, we implement organisational and technical measures to ensure that personal data is protected against accidental or unlawful destruction (e.g., backups on a regular schedule), alteration, disclosure, and any other unlawful processing. Nevertheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. Therefore, we recommend you to process your Personal Data responsibly (use strong passwords so that access to data would be restricted, be wary of suspicious e-mails and messages, restrict the access to your Personal Data, etc.).

Data disclosure

We never share Personal Data of the user with third parties. As it was mentioned before, for processing your payment, your personal and payment details are processed by Stripe. For more details, please refer to the Stripe privacy policy.

Where necessary (e.g., when we are required to comply with applicable laws), we may transfer and/or otherwise disclose your personal data to the law enforcement authorities, courts and other authorised governmental bodies.

When you communicate with us via social networks, you should inquire about their applicable data protection terms and conditions and read their privacy policy. All personal data you provide to us via social networks is controlled and managed by that particular social network:

Twitter, Inc. (USA). Please find the respective data protection policy here.
GitHub, Inc. (USA). Please find the respective data protection policy here.

If at some point Coinwink, as a business, is sold, the transfer of the users' Personal Data to the new business owner will be done under similar "privacy-focused" conditions.

Rights of the data subject

You have the right to request access to your personal data and to request rectification, erasure or restriction of the processing of personal data. If you have given us your explicit consent to the processing of your data, you can withdraw it by using the appropriate functionalities of the App.

Where the processing of your data is based on our legitimate interest, you have the right to object to the processing of your data.

You can exercise rights over your data by reaching out to moc.kniwnioc@ofni.

If you believe that CoinWink is unlawfully processing your personal data or is not implementing your rights, you have the right to file a claim before the responsible Data Protection regulatory authority, in particular, before the Lithuanian State Data Protection Inspectorate (L. Sapiegos street 17, 10312 Vilnius, [email protected]).

Cookies

To ensure the proper functioning of the website, we use cookies to collect information.

What are cookies?

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web-app and stored on your computer's hard drive.

Why are cookies used?

Cookies help the website to remember your actions and settings for a certain period (e.g., language preference, time, duration of visit, etc.) so that you do not have to re-enter them each time you visit the website or browse its individual pages. Cookies may also be used to collect anonymous browsing statistics.

Can I refuse the cookie?

Please note that deleting and blocking Cookies may have an impact on your user experience. Nevertheless, you can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

What cookies does Coinwink use?

We use Necessary cookies and Statistical cookies:

Necessary cookies help a website function properly by enabling basic functions (i.e., page navigation and access to secure areas of the website).
Statistical cookies help a website owner to understand how visitors interact with websites by collecting and reporting information anonymously.

These cookies are used on this website:

__cf_bm (Necessary, 1 day)
To manage incoming traffic that matches criteria associated with bots
XSRF-TOKEN (Necessary, 1 day)
To ensure visitors‘ browsing security by preventing cross-site request forgery
_ga (Statistical, 2 years)
_gid (Statistical, 1 day)
_gad (Statistical, 1 day)
Used by Google Analytics to evaluate your use of our App. These cookies are used to collect information and report App usage statistics without personally identifying individual visitors.
Here you can find more information about Google Analytics cookies.

Changes to this Privacy Policy

This Policy is effective as of 14, September 2022 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Policy at any time and you should check this Policy periodically. Your continued use of the service after we post any modifications to the Policy on this page will constitute your acknowledgment of the modifications.

If you have any questions regarding this Policy, please contact us via moc.kniwnioc@ofni.