Privacy Policy

Effective date: 30 April 2024

Introduction

This Privacy Policy sets out how we collect, use, store, transfer, and protect the Personal Data that you provide or that is otherwise received by us.

For the purposes of this Privacy Policy, “we”, “us”, and “our” refer to [BLOCKHOUND name, address, number] as to the Controller of your Personal Data, and "you", “User”, "your" refer to you as to the Data Subject.

This Privacy Policy applies to the User’s usage of the Website and the submission of the request for the Services.

You agree that you have read, understood, and agreed to be bound by this Privacy Policy.

If you disagree with this Privacy Policy, you are expressly PROHIBITED using the Website and Services, so you must discontinue use immediately.

The Processing of Personal Data in regard to the provision of Services and related payments is governed under an individual services agreement with the User construed on the basis of the Terms of Service available at [link].

Terminology

Consent

Any freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes signifies agreement to the Processing of Personal Data.

Controller

The natural or legal person (and others) who determines the purposes and means of Processing. For the purposes of this Privacy Policy, the Controller is the [BLOCKHOUND].

Cookie Policy

The agreement between you and us that describes how we use and process Cookies, available at: [link].

Data Protection Authority

The Federal Data Protection and Information Commissioner (FDPIC).

Data Subject

The natural person whose Personal Data is processed.

Legal Grounds for Processing

One of the legally defined grounds for which the Processing of Personal Data is permitted.

There are the following reasons:

Consent.
Legitimate interest.
Obligation.

Personal Data

Any information relating to an identified or identifiable natural person.

Personal Data Breach

A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored, or otherwise Processed.

Processing

Any action or set of actions with Personal Data.

Profiling

Any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.

Services

The services we offer and provide are defined under an individual services agreement with the User construed on the basis of the Terms of Service.

Third-Party

Any person, except the Data Subject, us, and the Data Protection Authority, to whom the Personal Data is transferred.

Website

The website is owned by us and is located at: [Website address].

Data Subject’s Rights

You have the following rights as a Data Subject, subject to existing limitations and exemptions under the applicable law:

Right to access Personal Data

You can receive information regarding specific Personal Data we have collected about you.

Right to rectification of Personal Data

You can correct your Personal Data if it has been changed or incorrectly collected.

Right to erase (deletion) Personal Data

We may stop Processing your Personal Data and delete applicable Personal Data from the information systems.

Right to restrict the Processing of your Personal Data

You may limit us from Processing Personal Data.

Right to Personal Data portability

You may receive Personal Data in a human and machine-readable format for transmission to another Controller.

Right to withdraw consent

You can withdraw your consent on Personal Data Processing if we use this ground for Processing.

Right to ask a question and/or make a claim on Data Processing

You are allowed to ask us any question related to Personal Data Processing or file a claim with the Data Protection Authority.

Principles Of Data Processing

We process Personal Data according to the following principles: 

Lawfulness, Fairness, and Transparency

Personal Data must be processed lawfully, fairly, and transparently. 

Purpose Limitation

Personal Data must be collected for specified, explicit, and legitimate purposes and not further processed in an incompatible manner. 

Data Minimization

Personal Data must be adequate, relevant, and limited to what is necessary concerning the purposes for which they are processed. 

Accuracy

Personal Data must be accurate and, where necessary, kept up to date. 

Integrity and Confidentiality

Personal Data must be processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful Processing and accidental loss, destruction, or damage.

Data Subject’s Rights Enforcement

Data Subject Request Form

The User can enforce his rights by contacting us via the following email: [email address].

Verification Methods

The specific verification method we use is the request for information.

Failed Verification

If the User fails verification or we have reasonable personality doubts, we shall provide a message stating that we have doubts, why we have these doubts, and why, in this case, we cannot respond.

Successful Verification

We will respond to the request if the User successfully passes the verification.

Personal Data Collection

Website Visit

When the User visits the Website, the User gives us the Personal Data under the following conditions:

Personal Data

A version of a web browser, IP address, time zone, and information about the interactions with the Website.

Purpose of collection

To load and operate the Website accurately.

Source of collection

Collected automatically when you access and interact with our Website.‍

Legal ground

Legitimate interest.

Terms

While the User is using the Website and 3 years after, unless we need to have the Personal Data longer under our obligation.

Request Submission

When the User submits the request via the form, the User gives the Personal Data under the following conditions: 

Personal Data

Category of problem, full name, email, location, wallet addresses and networks, quantity of virtual assets and their names, address for correspondence, and other additional details indicated by the User.

Purpose of collection

To provide our Services.

Source of collection

Collected automatically when the User submits the request form.

Legal Ground

Consent.

Terms

While the User is receiving the Services and 3 years after unless we need to have this Personal Data longer under our obligation.

Customer Support Information

When the User contacts our customer support, the User gives us the Personal Data under the following conditions: 

Personal Data collected

It depends on a case-by-case basis but can include name, email, wallet address and other information.

Purpose of collection

To provide information about our Services, consult how to use our Services.

Source of collection

Collected from the User.

Legal ground

Consent.

Terms

3 years after the User contacted our support unless we need to have this Personal Data longer under our obligation.

Other Conditions

These are other conditions apply to your Personal Data: 

Data source

We process Personal Data received from you. If, in the future, we process Personal Data obtained from Third Parties, we will notify you of this.

Profiling

We do not use Profiling on you.

Data storage and deletion

We keep your Personal Data only for as long as is necessary for the purposes for which it was collected. Your Personal Data is stored on servers of AWS. For more information, please refer to AWS Data Privacy.

Cookies

We use cookies in accordance with the Cookie Policy available at: [link].

How We Protect Personal Data

We maintain administrative, technical, and physical safeguards designed to protect the Personal Data we have about you against accidental, unlawful, or unauthorised destruction, loss, alteration, access, disclosure, or use.

We have implemented appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed unauthorizedly, altered, or disclosed. In addition, we limit access to your data to Third Parties.

We have put in place procedures to deal with any suspected Personal Data Breach and will notify you and the Data Protection Authority of a Data Breach.

Data Breach Notification

Notifying the Data Protection Authority

We shall notify the respective Data Protection Authority as soon as practically possible after we become aware of the Data Breach and report the following information: 

The nature of the Data Breach.
The name and contact details of the responsible person from whom more information can be obtained.
The possible consequences of the Data Breach.
The measures taken or proposed by us to address the Data Breach.

Notifying You

We shall immediately inform you of the fact of the Data Breach if this is required for the protection and report the following information: 

The nature of the Data Breach in clear and straightforward language.
The responsible person's name and contact details from which more information can be obtained.
The possible consequences of breaching the security of Personal Data.
The measures taken or proposed by us to address the Data Breach.
Useful tips and know-how that can help you reduce the risks of a Data Breach.

Exemptions

We may limit, delay or dispense with the provision of information about the Data Breach to the Data Subject if:

There is a reason for doing so pursuant to Article 26 paragraph 1 letter b or paragraph 2 letter b of the Data Protection Act of Switzerland, or the provision of information is prohibited by a statutory duty of confidentiality;
The provision of information is impossible or requires disproportionate effort; or
The provision of information to the Data Subject is equally guaranteed by making a public announcement.

Miscellaneous

Effective Date

This version of the Privacy Policy is valid from the Effective Date.

Changes

We may make changes from time to time without your consent. The new version will be valid from the time of the changes noted at the beginning of this Privacy Policy.

Governing Law and Dispute Resolution

This Privacy Policy is construed in accordance with the legislation of Switzerland. All disputes and disagreements arising between the User and us in connection with this Privacy Policy shall be settled through negotiations. In the event disputes cannot be settled within 20 (twenty) calendar days, the resolution of such disputes shall be attributed to the competent courts of Switzerland with Swiss law as material and procedural legislation.

Headings

The headings are just to help you understand what each section is about, and they will not change the meaning of anything. Using words like “including” or “such as” doesn't mean we have listed everything that could be included.

Languages

This Privacy Policy is available in English. If there are any differences between the English and any other translated versions, the English version shall prevail.

Questions And Concerns

If you have any questions about privacy and our Privacy Policy, please contact us through our support: [email address].

You can ask the Data Protection Authority any question about your Personal Data or make a complaint. The timing and procedure for responding depend on the internal policies of the Data Protection Authority.