Privacy Policy

This Privacy Policy describes how your personal data is collected and processed by Keytom Services and its affiliates when you, a natural person, user of www.keytom.com website (the “Website”).

To make this Privacy Policy easier to read, our Website, any services or interfaces accessible via the Website, including without limitation the purchase, sale, exchange of certain digital assets and online offerings related to the Website, are collectively referred to as the “Services.”

We ask that you read this privacy policy which was last updated on the date set out below (the “Privacy Policy”) carefully as it contains important information on who we are, how and why we collect, store, use, transfer and share personal information, your rights in relation to your personal information, and how to contact us and supervisory authorities in the event you have a complaint. This Privacy Policy should be read alongside, and in addition to any separate product or service agreement entered into between us from time to time.

Whenever we refer to the “law” under this Privacy Policy we are referring to those laws all as amended from time to time. Where we have used but haven’t explained the meaning of a defined term in this Privacy Policy, that defined term has the same meaning as set out under Terms & Conditions. When we refer to “information” or “data” under this Privacy Policy we refer to your personal information.

We collect your personal information when you visit, use or interact with us online, and through our ads displayed through online services operated by us or non-affiliated third parties. We may use or share personal information collected to deliver products and services to you and for advertising purposes.

By browsing, accessing or using the Website you hereby unconditionally agree with this Privacy Policy.

The terms "Company", "we", "us", "we", "our" or Keytom Services refer to the following companies:

KEYTOM SERVICES ltd. registered in the Province of British Columbia, Canada under registration number BC1291639, whose registered office is located at 346 LAWRENCE AVE #202, OFFICE I, KELOWNA, BC, CANADA V1Y6L4,

KEYTOM GLOBAL HOLDING LIMITED , a company duly registered in DIFC with its registered office located at Dubai International Financial Centre, Burj Daman, Level 5, Unit no. C502H, Dubai, UAE, reg. nr. 7849, and
Keytom Solutions s.r.o. (registration number 212 34 124) with VASP authorisation in the Czech Republic, registered at Frydlantská Str., No. 1312/19, Kobylisy, ZIP code: 182 0, Prague 8.

This Privacy Policy is governed by applicable Canadian and EU laws and regulations. This policy is established to ensure that KEYTOM SERVICES complies with the Personal Information Protection and Electronic Documents Act of Canada (PIPEDA) and the European Union General Data Protection Regulation (GDPR) as well as Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data and Data Protection Law, DIFC Law No. 5 of 2020, DIFC Data Protection Regulations 2020..

This Privacy Policy shall be regulated by applicable laws and regulations of Canada and the EU regulation. This policy is established to ensure compliance of KEYTOM SERVICES with the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada and the European Union's General Data Protection Regulation (GDPR) and the UAE Federal Personal Data Protection Law (PDPL).

Personal Information Protection and Electronic Documents Act (PIPEDA) regulations shall be implemented for Canada users. General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) and the Data Protection Act 2018 regulations shall be implemented for EU users. Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data and Data Protection Law, DIFC Law No. 5 of 2020, DIFC Data Protection Regulations 2020 shall be implemented for UAE users.

The Company undertakes maximum efforts in order to protect your privacy. The Company uses the collected information about you to fulfill its contractual obligations and improve the customer service.

All the terms that have definitions in Terms and Conditions shall have the same meaning in this Privacy Policy. “Personal data” and “Personal information” shall mean any information relating to an identified or identifiable living individual.

We ask for your consent when required, otherwise by using our Website, you consent to the collection, use and sharing of your personal information subject to and consistent with applicable laws and other notices you may have received based on your relationship with us.

PLEASE READ THE PRIVACY POLICY CAREFULLY BEFORE CREATING YOUR ACCOUNT. IF YOU DO NOT AGREE WITH ALL OR ANY THESE TERMS, PLEASE LEAVE THE WEBSITE IMMEDIATELY.

1. COLLECTION OF YOUR PERSONAL DATA

1.1. Personal data we may collect. The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

1.1.1 Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

Account Creation. We may collect information when you create an account with us, such as name and email address. We may also require that you provide additional identity and verification information.

Wallet and Transaction Information. In order to engage in transactions on the Services, you may need to provide us or our third-party payment processors with access to or information about your digital wallet. We will never ask you or collect your private keys.

Other Transactions. We may collect personal information and details associated with your activities on our Services.

Your Communications with Us. We may collect personal information, such as email address when you request information about our Services or otherwise communicate with us.

Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., via the community on Discord, messaging and chat features, and social media pages). Any personal information you provide on the public sections of these features will be considered “public,” (the “User Content”) unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

Sweepstakes, Giveaways or Contests. We may collect personal information you provide for any sweepstakes, giveaways or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

1.1.2 Information Collected Automatically

We may collect personal information automatically when you use our Services:

Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), Internet service provider, and metadata about the content you provide. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

Cookie Policy for Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

Pixel Tags/Web Beacons and Other Technologies. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;

Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);

Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transfer-related emails regarding services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms & Conditions or this Privacy Policy).

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others. Please note you must separately opt out in each browser and on each device.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.  

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; or (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (aka the right of data portability);

Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

Request Deletion of your personal information;

Request Restriction of or Object to our processing of your personal information, including where the processing of your personal information is based on our legitimate interest or for direct marketing purposes; and

Withdraw Your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us. We will process such requests in accordance with applicable laws.

Analytics. We may use our Technologies and other third-party tools to process analytics information on our Services. These technologies allow us to process usage data to better understand how our Services are used, and to continually improve and personalize our Services. Some of our analytics partners include:

Google Analytics. For more information about how Google uses your data (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy.

Social Media Platforms. Our Services may contain social media buttons, such as Discord, Snapchat, Twitter, and Telegram, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

1.1.3 Information Collected from Other Sources

Third-Party Sources. We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

2. USE OF YOUR PERSONAL DATA

2.1. We use your data for the following purposes:

2.1.1 To fulfill the obligations and to provide you with the services for which we have received your consent;

2.1.2 To understand your needs and preferences in using our services, to evaluate and understand the effectiveness of advertising materials that we provide;

2.1.3 To develop new and enhance existing service and product offerings, to notify you about changes related to our services;

2.1.4 To verify and check the identity of users who open and operate accounts in order to prevent fraud, deception, and other illegal activities;

2.1.5 To comply with legal requirements for anti-money laundering and counter-terrorist financing;

2.1.6 To ensure the security of our website, our services, and your account.

2.1.7 To support, respond and resolve your complaints and issues related to use of our services and the capabilities of our website.

2.1.8 Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

Automated Decision Making.  We may engage in automated decision making, including profiling. Our processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us.

De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

2.2. We use aggregated personal data to understand how our users use our services, provided that those data cannot identify any individual. We also use third-party web analytics tools that help us understand how users engage with our website.

3. DISCLOSURE OF YOUR PERSONAL DATA

3.1 We may share your information with selected third parties including:

3.1.1 business partners, suppliers and independent contractors for the performance of any contract we enter into with them or you;

3.1.2 advertisers and advertising networks (only aggregated personal data);

3.1.3 analytics and search engine providers that assist us in the improvement and optimization of services;

3.2 We may also disclose your personal data if:

3.2.1 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or other terms; or to protect the rights, property, or our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

4. SECURITY AND STORAGE OF YOUR PERSONAL DATA

4.1. We have implemented security measures to ensure the confidentiality of your personal data and to protect your data from loss, misuse, alteration or destruction. Only authorized representatives have access to your personal data, and these representatives are required to treat the information as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

4.2. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

4.3. We will not sell, rent or lease your information to third parties. However, we may share your information with trusted third parties to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to us, and they are required to maintain the confidentiality of your information. We will not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

4.4. Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

4.5. We will keep your personal information as long as you are a client of Keytom Services We may keep your personal information for up to 5 years after you stop being a client. The reasons we may do this are:

• to respond to a question or complaint, or to show whether we gave you fair treatment;
• to study customer data as part of our own research;
• to comply with legal rules that apply to us about keeping records.

We may also keep your data for longer than 5 years if certain laws mean that we cannot delete it for legal, regulatory or technical reasons.

5. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to the Canada, EU or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

6. USE OF COOKIES

6.1. We may use cookies to distinguish you from other users of our products or services. This helps us to provide you with a good experience, and also allows us to improve our products or services. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device when you visit our website. Cookies send information back to the originating website on each subsequent visit, or to another website which recognizes that cookie. Cookies also make it easier for you to log in and use our website.

6.2. We may use the following cookies:

• Strictly necessary cookies required for the operation of our products or services (including, for example, cookies that enable you to log into secure accounts and use interactive features);
• Analytical/performance cookies that allow us to recognize and count the number of visitors and users and see how they use the products or services (e.g. (without limitation) to help us improve the way our products or services work or are provided, by ensuring that users are finding what they are looking for easily);
• Functionality cookies to help us recognize you when you return to our Website (this enables us to e.g. (without limitation) personalize our content for you, greet you by name and remember your preferences, such as choice of language or region).
• Targeting cookies to record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our products and services and the information displayed on it, which we reasonably think is more relevant to your interests. We may also share this information with third parties for this purpose.

6.3. You can block or disable cookies by activating the setting on your website browser that allows you to refuse the setting of all or some cookies. All browsers provide tools that allow you to control how you handle cookies: accept, reject or delete them. These settings are normally accessed via the ‘settings’, ‘preferences’ or ‘options’ menu of the browser you are using, but you could also look for a ‘help’ function or contact the browser provider. However, if you set your browser settings to block or disable all cookies (including essential cookies) you may not be able to .

7. MISCELLANEOUS

7.1. The Privacy Policy shall remain in full force and effect while you use Website.

7.2 The Company reserves the right to modify the Privacy Policy at any time at the Company’s sole discretion. They will notify you about amendments by automatic notification on the Website, but will not ask any actions to confirm that you agree. If you do not agree with the new amended version, then you must immediately discontinue your access to Website and stop use all the services. If you continue to use the services, the amended Privacy Policy have legal force for you and your actions will constitute acceptance of the amendments.

7.3. Under the GDPR, you are entitled to the following rights:

• question any information about you that you think is incorrect and have us take reasonable steps to correct it for you.
• to be told about how we process your information.
• require the erasure of personal information concerning you in certain situations
• access personal information and copies (free of charge, where reasonable for us to do so at the time) concerning you collected by us in the course of our relationship with you
• object at any time to processing of personal information concerning you for e.g. (without limitation) direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or which similarly may significantly affect you
• object in certain other situations to our continued processing of your personal information
• otherwise, restrict our processing of your personal information in certain circumstances
• The right to move, copy or transfer your personal data (where reasonable and proportionate for us to do so).

7.4. Under the Personal Information Protection and Electronic Documents Act (PIPEDA), you are entitled to the following rights:

• You have the right to access your personal information held by organizations subject to PIPEDA. This includes the right to know what personal information is being collected, how it's being used, and to whom it's being disclosed.
• You have the right to give or withhold consent for the collection, use, and disclosure of your personal information by organizations subject to PIPEDA. Consent must be informed, voluntary, and can be withdrawn at any time.
• You have the right to ensure that your personal information held by organizations subject to PIPEDA is accurate, complete, and up-to-date. You may request corrections to any inaccuracies.
• You have the right to challenge an organization's compliance with the principles outlined in PIPEDA, including how your personal information is collected, used, or disclosed.
• You have the right to expect that your personal information will be protected by appropriate safeguards against loss, theft, unauthorized access, disclosure, copying, use, or modification.
• You have the right to hold organizations accountable for their handling of your personal information. Organizations must appoint individuals responsible for ensuring compliance with PIPEDA and provide avenues for recourse if privacy rights are violated.
• You have the right to withdraw consent for the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions and reasonable notice.

7.5.  In accordance with the Personal Data Protection Act, Federal Law No. 45 of 2021 on the protection of personal data, you have the following rights:

• Right of access to information. You have the right to receive information about the categories of personal data processed, the purposes of processing, decisions taken on the basis of automated processing, organisations to which personal data are transferred.
• The right to request the portability of personal data. You have the right to receive your personal data in a structured and machine-readable format.
• The right to rectification or erasure of personal data. You have the right to have inaccurate personal data corrected, as well as the right to have your personal data erased and the right to be forgotten.
• Right to restriction of processing. You have the right to restrict and stop the processing of your data if it is inaccurate or you object to the purposes of the processing.
• The right to processing and automated processing. You have the right to object to automated decisions taken by automated processing of your personal data.

7.6. If you are located in the European Economic Area, Switzerland, or the United Kingdom you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

7.7. The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us.  If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information.

7.8. You can withdraw your consent to our processing of your information at any time. Please contact us if you want to do so at: privacy@keytom.io. This will only affect the way we use information when our reason for processing your information is that you have provided your consent to that use. If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you. You then have the option to give us your consent again if you want to access our products or services.

7.9. We will employ adequate technical and organizational security measures to protect your personal information. We will use reasonable effort to ensure that your personal data is accurate, complete and up-to-up-date. Please ensure you notify us without undue delay of any changes to the personal data that you have provided to us by updating your details on the Platform or by contacting us at the details provided in this Privacy Policy.

7.10. By accessing the Website or using any of our products or service, you consent to and authorize the export of personal data to the Company and its storage and use as specified in this Privacy Policy.

This Privacy Policy shall be governed by, construed and entered in accordance with the laws of the Canada applicable to contracts deemed to be made within such state, without regard to choose of law or conflict of law provisions thereof. The exclusive jurisdiction for all disputes between you and the Company will be the state and federal courts located in the British Columbia, and You and the Company each waive any objection to jurisdiction and venue in such courts.

YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

7.11. We are responsible as “controller” of that personal information for the purposes of those laws. If you have any queries about this Privacy Policy or how we (may) collect, store or use your information, please contact us by email at privacy@keytom.io