Privacy policy

Introduction

bitpass (bitpass .ai”) is dedicated to protecting your personal information and informing you about how we use your information. This Privacy Policy applies to the bitpass owned websites (including bitpass .ai), bitpass mobile applications available for download on a third party mobile store, any related components or services, and the content we make available through our platform (collectively referred to as the “Platform”).

This Privacy Policy should be read in conjunction with our other legal agreements with you. Please review this Privacy Policy periodically as we may revise it from time to time. If you do not agree with or accept our Privacy Policy in its entirety, you must not access or use the Platform.

If you use the Platform following a change to the terms of this Privacy Policy you agree to accept the revised policies.

Information Collected

At bitpass ,we collect personally identifiable information (“PII”) that may be submitted, collected via your interactions with the Platform, or through the use of tracking technology including cookies. PII is either submitted or collected and is described as follows:

PII Submitted

You will not be required to provide us any information when you visit our Platform. Where you submit a request for us to contact you or you create an account we may collect PII such as your email and social media information provided by your login with third party platforms, including Facebook, Google, and Apple. If you log in to our websites or online services via a third party site, such as Facebook, that site may pass information to us, such as user ID, name associated with the ID, email address and location, plus other information as described in that website's privacy policy. Our Platform may also return information about you to that social networking site regarding your log in, such as which of our websites and apps you visit and use, and your use of social media services on those websites and apps. Where you submit information in this manner you consent that we may contact you via the PII provided.

PII Collected

Whenever you use our website or applications, we may collect automatically collect PII either from your interactions with the Platform or via tracking technologies (cookies and web beacons) which includes information such as your IP address , browsing history, registration history, interactions with the Platform, usage information, location, referring URL, browser, operating system, data usage, data transferred, computer or device information, Internet service provider, and device or user unique identifiers.

3. Use of Your Information

We use your PII for the following purposes:

  • To provide any services offered and to operate bitpass Platform.
  • To enhance or improve our users’ experiences.
  • To to contact you via email or other electronic communications where you have an inquiry.
  • To notify you of additional bitpass services and updates.
  • To share your information with third party partners for marketing and analytic purposes or third parties hired by us to perform functions and provide services to us subject to the obligations consistent with this Privacy Policy and on the condition that the third parties use your information only on our behalf and pursuant to our instructions.

4. Accessing, Editing, and Removing Your Information

If you have any questions or wish to review, remove, change, or access any of your information collected by us, please contact us support@bitpass.ai . Any requests to delete or modify information shall be subject to our right to retain such information for business or legal purposes.

5. Cookies and Tracking

We use cookies as stated within our Cookie Policy. Cookies must be enabled in your browser in order for our Platform to function properly. If you disable cookies from your web browser some portions of our Platform may not work. Our Cookie Policy is integrated into the Privacy Policy.

6. Third Party Access to Your Information

Although you are entering into an Agreement with bitpass to disclose your information to us, we do use third party individuals and organizations to assist us, including contractors, web hosts, marketers, customer service organizations, and others to allow you to access the Platform.

7. Law Enforcement

You agree that we may disclose your information to authorities if compelled to by a court order. Additionally, you agree that we may disclose your information if we reasonably believe that you have violated United States’ federal and state laws, the terms of any legal agreements you have with us or our Privacy Policy, or if we believe that a third party is at risk of bodily or economic harm. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you and release your information without receiving any request to third parties where we believe that it is proper to do so for legal reasons, where your actions violate any law of the United States or any other country having jurisdiction over us, our Platform, or our Privacy Policy. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants. We may release your information under the conditions listed in this paragraph whether it is to individuals or entities and to any state or federal authorities, as required.

8. Opt Out of Commercial, Non-Commercial Communications and Do Not Track

If you decide to provide us with your contact information, you agree that we may send you communications via text and emails where you have opted into such communications. However, you may unsubscribe from certain communications by notifying bitpass that you no longer wish to receive these communications, we will endeavour to promptly remove you from our once we have received that request. We currently do not offer functionality for you to opt out through “do not track” listings as no DNT standard has been adopted.

9. Third Parties

The Platform may have links to third party websites, which may include information that we have no control over. When accessing a third party site through our Platform, you acknowledge that you are aware that these third party websites are not screened for privacy or security issues by us, and you release us from any liability for the conduct of these third party websites. We bear no responsibility for the information collected or used by any advertiser or third party website. You must review such third parties terms of use or privacy policy to understand how their information collection practices work.

10. Security Measures

We make reasonable attempts to protect your information by using physical and electronic safeguards such as data encryption, user authentication, password verification, and physical barriers. However, as this is the Internet, we can make no guarantees as to the security or privacy of your information. For this reason, we recommend that you use anti-virus software, routine electronic security checks, firewalls, and other precautions to protect yourself from security and privacy threats.

11. Your California Privacy Rights

bitpass permits residents of the State of California to use its Platform, and complies with the California Business and Professions Code §§ 22575-22579. If you are a California resident you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes. Various provisions throughout this Privacy Policy address requirements of the Californian privacy statutes. Although we do not disseminate your information to third parties without permission, you must presume that we collect electronic information from all visitors. You may contact us at support@bitpass.ai with any questions.

12. Age Compliance

We intend to fully comply with American and international laws respecting children’s privacy including COPPA. Therefore, we do not collect or process any information for any persons under the age of 13. If you are under 13 and using our Platform, please stop immediately and do not submit any information to us. In the event that we have inadvertently collected any information from users under the age of 13, please contact us immediately.

13. International Transfer

Your information may be transferred to - and maintained on - computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. PII that is submitted to bitpass will be collected, processed, stored, disclosed and disposed of in accordance with applicable U.S. law and this policy. If you are a non-U.S. member, you acknowledge and agree that bitpass may collect and use your PII and disclose it to other entities outside your resident jurisdiction. In addition, such information may be stored on servers located outside your resident jurisdiction. U.S. law may not provide the degree of protection for information that is available in other countries.

14. Merger and Acquisition

In the event that bitpass is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. Please be aware that once the information is transferred your privacy rights may change.

15. Amendments

We may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will modify the date listed or we may contact you. You must agree to the amendments as a condition of your continued use of our Platform. If you do not agree, you must immediately cease using our Platform.

16. Privacy Notice for European Citizens

We respect the rights of persons living within the European Economic Community (EEC) and the rights afforded to them under the General Data Protection Regulation (GDPR), the sections 16-22 are referred to as our Privacy Notice and address additional privileges that EEC users may have under our Privacy Policy. This Privacy Notice explains how we shall assist our users who live within the EEC.

If you wish to exercise any of these rights or have questions about any of these rights please contact us at the information listed below.

17. Legitimate Purposes for Collecting Your PII

For the purposes of this Privacy Notice “personal data” as defined under the GDPR shall mean PII as defined in this Privacy Policy. The following are the specific legitimate purposes that we may use your PII for:

  • Contract Administration - We may use your PII to (1) negotiate, execute, renew and/or manage a contract with you; and/or (2) communicate with you in respect of the above (including sending (legal) notifications). (Performance of Contract)
  • Access and Communications to Our Platform – (1) interact with you through our Platform; (2) communicate with you regarding updates or in response to inquiries; and/or (3) manage and respond to your questions or comments (e.g. technical, commercial or administrative) or requests for maintenance and support. (Legitimate Interest)
  • Use of the Platform - We may use your PII to (1) enable you to enjoy the use of, and easily navigate the Platform; (2) to understand how our Platform functions with you; and (3) to share with third parties we hire to maintain our Platform (Legitimate Interest)
  • Direct Marketing and Third Party Marketing - We may use your PII to contact you for additional products and services that you have expressed interest in. (Consent)
  • Training and Improvements - We may use your PII to (1) train our employees or contractors to allow for a better Platform experience; and/or (2) improve the Platform. (Legitimate Interest)

Please be aware that all legitimate purposes will be taken with minimal amounts of additional processing. Aside from the purposes listed, we may share your information where investigations or a legal dispute has occurred in accordance with our Privacy Policy (Legal Obligation).

18. Basis for Data Processing

Your PII is processed by bitpass manually and/or using our Platform tools and third party providers as described in this Notice. bitpass shall process such PII for specific purposes and only where there is a specific legal basis for doing as described above in Section 17.

19. Retention of Personal Information

bitpass will only retain your PII for as long as required and proportionate to the use of your PII. We will keep your personal information:

  • For any legally required duration
  • Upon your request to eliminate, delete, or modify any of you PII stored with us, we will honor such legitimate request.
  • Until we no longer have a valid reason to keep or use your PII.

Where you have requested modification or deletion of your PII, we may keep just enough of your personal information to ensure that we comply with your requests not use your personal information or comply with your right to erasure subject to any legal obligations or legitimate interests. If you require additional details regarding the retention of your PII please contact us.

20. Security and Transfer of PII Outside of the EEC

Your PII is subject to the security provisions found within this Privacy Policy and the security measures we take are in line with industry standards. When you submit PII to us your PII may be transferred and stored in the United States. bitpass shall ensure that your PII shall have an adequate level of protection and that your information will be accessible as stated under the Privacy Notice. In order to facilitate such a transfer under the GDPR, we rely on EU Standard Contractual Clauses (“SCCs” also called Model Clauses) published by the European Commission to protect your PII. These are standard form data export agreements that have been approved by the European Commission as a lawful basis for transferring PII to non-EEA countries like the USA. By submitting any PII to us you agree to be bound the SCCs (which are integrated into this Privacy Policy) and found here.

21. Sharing of Data with Third Parties

We may disclose your personal information to a third party as described below subject to the legitimate purpose as specified within the Privacy Notice. We have entered into agreements (including but not limited to Data Protection Agreements) with all third parties that we disclose your personal information to and they are prohibited from selling such personal information.

We share your PII with the following third parties:

Data ProcessorPurpose of SharingPrivacy Policy
WinkUse of Platform; User authentication; Payment Gatewayhttps://wink.cloud/privacy-policy
GoogleUse of the Platform; Training and Improvements https://policies.google.com/privacy
Firebase AnalyticsUse of the Platform; Training and Improvementshttps://firebase.google.com/support/privacy
HotjarUse of the Platform; Training and Improvements https://www.hotjar.com/legal/policies/privacy/
FacebookUse of the Platform; Direct and Third Party Marketing; Contract Administration https://www.facebook.com/privacy/explanation

22. Data Controller Information

If you are an EEC resident and you have any questions regarding your rights under this Notice or wish to exercise any rights as enumerated under the GDPR, please contact us at: support@bitpass.ai or

bitpass registered address

NYKL INC.

205 Lakeside Cir

Murphy

Texas

United States

support@bitpass.ai

Please label any email communications with the title “GDPR Request”.

23. How We Collect Your Personal Information

The Platform may collect your personal information in the following ways: (1) directly from your submission of such personal information; and/or (2) indirectly from your use of the Platform or observing your actions or interactions with the Platform.

24. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the personal information to us and to provide you with the full functionality and access to the Platform
  • To use as disclosed with Section 3 of our Privacy Policy.
  • To share with companies that we employ to provide services to the Platform or for marketing purposes.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

25. Sharing Personal Information

bitpass may disclose your personal information to a third party for a business purpose, as required, so that we may provide you with access to the Platform, allow you to interact with the Platform, and to understand how you use our Platform. This chart explains in detail how we disclose your personal information to third parties:

Category of Personal Information CollectedSource(s) from which that information may be collectedBusiness PurposeCategories of Third Parties to which bitpass shares this personal information
Email bitpassTo operate our Platform, enter into a contract, and to provide you with servicesData processing and analytics vendors; Customer service vendors
IP Address bitpassDeliver Advertising and to understand your Platform usageData processing and analytics vendors; Advertising vendors
Interactions bitpassTo understand your Platform usage and to improve our PlatformData processing and analytics vendors
User and Device Identifiers (i.e. Google Advertising ID) bitpassDeliver Advertising and to understand your Platform usageData processing and analytics vendors; Advertising vendors
Usage History bitpassTo understand your Platform usage and to improve our PlatformData processing and analytics vendors; Advertising vendors
Registration History bitpassTo understand your Platform usage and to improve our PlatformData processing and analytics vendors; Advertising vendors
Locations bitpassTo understand your Platform usage and to improve our Platform; Deliver AdvertisingData processing and analytics vendors; Advertising vendors
Referring URL bitpassTo understand your Platform usage and to improve our Platform; Deliver Advertising Deliver Advertising Data processing and analytics vendors; Advertising vendors
Browser bitpassTo understand your Platform usage and to improve our Platform; Deliver AdvertisingData processing and analytics vendors; Advertising vendors
Operating System bitpass To understand your Platform usage and to improve our Platform; Deliver AdvertisingData processing and analytics vendors; Advertising vendors
Data Usage / Transferred bitpassTo understand your Platform usage and to improve our Platform; Deliver AdvertisingData processing and analytics vendors; Advertising vendors
Computer / Device Information bitpassTo understand your Platform usage and to improve our Platform; Deliver AdvertisingData processing and analytics vendors; Advertising vendors
Internet Service Provider bitpassTo understand your Platform usage and to improve our Platform; Deliver AdvertisingData processing and analytics vendors; Advertising vendors

26. Cookies

Cookie information can be found in our Cookie Policy.

27. Contact Information

If you have any questions or require additional information related to our information collection practices, please contact us at: support@bitpass.ai or Attn: Legal

bitpass registered address

NYKL INC.

205 Lakeside Cir

Murphy

Texas

United States