Revidert July 01, 2019
We are Reignfall Limited ("Data Controller", "we", "us", "our", "Reignfall Limited", "the Company", "Owner", "Operator").
We want you to obtain personalized experiences anytime, anywhere, on any device. This requires us to collect personal information from you. However, we want to put you in control of that personal information. We want you to be aware at all times where and how your personal information is being used. This is of paramount importance to us.
So let’s describe what this policy tells you. It explains:
At Reignfall Ltd we take your privacy seriously. We operate on the principle that your personal information belongs to you and only you can decide who you want to share it with and why. This is fundamental to the way we work and we’re committed to providing a secure environment for you to store your personal information and share it with others when you want to.
Information you voluntarily provide
If you contact us (by phone, email or through our website, or app), we may keep a record of that correspondence indefinitely in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.
If you report a problem with Koinly, we may keep that information indefinitely in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.
The information you give may include your name, address, telephone number and email address.
Information we collect about you and your device
Through your use of Koinly, you will be subject to different types of personal data collected and different manners of collection. We will collect and process your personal data in a lawful, fair, and transparent manner and, where appropriate, with your knowledge or prior explicit consent. Personal data will be relevant to the purposes for which they are to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
The following types of personal data will be collected by the Company through Koinly:
We may collect non-personal data, such as browser types, operating systems, and the URL addresses of websites clicked to and from Koinly, including referral links we may post on Koinly in order to analyze what kind of users visit Koinly, how they find it, how long they stay, from which other websites they come to Koinly, what pages they look at, and to which other websites they go from Koinly. In case your non-personal data are aggregated with certain elements of your personal data in the way that we may become able to identify you, such non-personal data will be treated as personal data.
We respect data protection principles and process personal data only for specified, explicit and legitimate purposes for which such personal data were provided. We primarily use your personal data to enable your use of Koinly and supply the services requested by you. We may also use your personal data for the following purposes:
Where we propose using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above.
We may share anonymized usage data which does not identify you specifically with third parties. We may combine your data with those of other users of Koinly and share this information in aggregated and anonymised form with third parties to help us improve the design and delivery of our software tools, increasing the effectiveness of all users.
From time to time, we may send you informational communications related to Koinly, such as announcements about updates to Koinly. you may also receive information from us that is specifically about your use of Koinly or about your account with us, including information about security breaches or other privacy-related matters. Please note that such communication does not fall within the scope of direct marketing communication.
After we obtain your explicit prior consent, we may use your personal data for direct marketing purposes, such as:
If you decide at any time that you no longer wish to receive communications from us, please follow the “unsubscribe” instructions provided in the communications, turn off communications in your settings page, or contact us at email@example.com.
Please note that we do not collect any sensitive data about you (e.g., your health information, opinions about your religious and political beliefs, racial origins and memberships of a professional or trade associations, social security number). Should we intend to process any sensitive data collected from you, we will seek your explicit consent in advance.
Protection of Personal Data
We protect your personal data by using reasonable security safeguards against loss or theft, unauthorized access, disclosure, copying, use, or modification. Your personal data are contained behind secured networks and are only accessible by a limited number of persons who have special access rights to such systems and are required to keep the personal data confidential. We implement a variety of security measures, such as encryption and pseudonymisation, when users enter, submit, or access their personal data to maintain the safety of your personal data. Please note, however, that no system involving the transmission of information via the Internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your personal data very seriously and we therefore take all reasonable steps to ensure the ongoing confidentiality, integrity, and availability of your personal data. Nevertheless, we are not liable for any loss, theft, unauthorized access, disclosure, copying, use, or modification of your personal data that occurs outside our reasonable control.
Should a personal data breach occur, we will inform the relevant authorities without undue delay and immediately take reasonable measures to mitigate the breach. We will notify you about such a breach via email as soon as possible but no later than within seven business days.
Your personal data will be kept for as long as it is necessary to provide you with the requested services. When your personal data are no longer necessary to deliver the requested services, we will delete your personal data immediately, unless we are obliged by law to retain such personal data for a specific period of time.
There are two types of cookies, namely, persistent cookies (i.e., cookies that remain valid until their expiration date, unless deleted by the user before that date) and session cookies (i.e., cookies that are stored on a web browser and remain valid until the moment when the browser is closed). We use both persistent cookies and session cookies.
Most Internet browsers accept cookies automatically, although you are able to change your browser settings to control cookies, including whether or not you accept them, and how to remove them. You may also be able to set your browser to advise you if you receive a cookie, or to block or delete cookies.
We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. Users can also choose to visit Koinly anonymously, but you may not be permitted to access any of the services.
We may disclose your information if we believe that it is reasonable to do so in certain cases, in Our sole and exclusive discretion. Such a disclosure or transfer is limited to the situations when the personal data are required for the purposes of (1) provision of the services, (2) pursuing our legitimate interests, (3) law enforcement purposes, or (4) if you provide your prior explicit consent. Please note that some third parties may be located outside of the jurisdiction in which you reside.
Such reasonable disclosure cases may include, but are not limited to:
We may utilize third party service providers, from time to time or all the time, to help us with Koinly and to help to serve you. Such third-party service providers may include:
Please note that some non-personal data may be provided to third parties for marketing, advertising, or other uses. We also allow third-party behavioral tracking which may include non-personal data.
From time to time, we may send you informational communications related to Koinly, such as announcements or other information. You may also receive information from us that is specifically about your use of Koinly or about your account with us, including information about security breaches or other privacy-related matters.
By providing any personal information to us, or by using Koinly in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from us or third-party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is legally defined.
Before visiting and providing any information to any such third-party websites and applications, you should familiarize yourself with the applicable privacy practices and take reasonable steps necessary to protect your personal data.
We take reasonable steps to ensure that the personal data collected and processed by us is accurate, complete, and up-to-date. Thus, we ask you to keep your personal data as current as possible and update your personal data through Koinly if necessary.
You may at any time review or change the personal data in your user account or terminate your user account by logging into it through Koinly and updating your personal data. Upon your request to terminate your user account, we will deactivate or delete your account and information from our active databases.
If you would like to access, modify, or delete your personal data that are processed through Koinly, please send us an email to firstname.lastname@example.org. We will answer your request within a reasonable timeframe.
We do not market to any individual under the age of 18 years old. Individuals under 18 years of age may not create an account on Koinly. However, we cannot distinguish the age of people accessing Koinly. If a person under 18 has provided us with personal data without obtaining parental or guardian consent in advance, the parent or guardian may contact us at email@example.com requesting us to destroy or de-identify the personal data.
When transferring data from the European Union, the European Economic Area, and Switzerland, Koinly relies upon a variety of legal mechanisms, including contracts with our Users. Koinly complies with the EU-U.S. and Swiss–U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the European Economic Area, and Switzerland to the United States. You can find Koinly’s Privacy Shield certification here (see Reignfall Limited). You can also learn more about Privacy Shield on its website.
Reignfall Limited is subject to oversight by the U.S. Federal Trade Commission. JAMS is the US-based independent organization responsible for reviewing and resolving complaints about our Privacy Shield compliance — free of charge to you. We ask that you first submit any such complaints directly to us via firstname.lastname@example.org. If you aren't satisfied with our response, please contact JAMS. In the event your concern still isn't addressed by JAMS, you may be entitled to a binding arbitration under Privacy Shield and its principles.
Within the scope of our authorization to do so, and in accordance with our commitments under the Privacy Shield, Koinly will provide individuals access to personal data about them. Reignfall Limited will also take reasonable steps to enable individuals to correct, amend, or delete personal data that is demonstrated to be inaccurate.
Koinly is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Koinly complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
After you submit such a complaint, we will send you an email within five business days confirming that we have received your complaint. Afterwards, we will investigate your complaint and provide you with our response within a reasonable timeframe.
If you are a resident of the European Union and you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
If the ownership of our business changes, we may transfer your information to the new owner so they can continue to operate Koinly and provide the Services. The new owners will be obliged to comply with this Policy.
Any changes we may make to this Policy will be posted on this page. Where it makes sense because the changes are material, we will notify you by email or in another appropriate manner such as when you next interact with Koinly.