KYC policy

1.1. General

In order to provide services to its Users, IZIBITS OÜ collects certain types of data from them. This section will describe how Users` data is collected and used by IZIBITS OÜ. Data entered or transferred into IZIBITS OÜ by Users such as texts, questions, contacts, media files, etc., remain the property of the User and may not be shared with a third party by IZIBITS OÜ without express consent from the User.

IZIBITS OÜ will process your account data you provide when you open IZIBITS OÜ account, perform transactions on the IZIBITS OÜ platform, or use other IZIBITS OÜ Services. This information may include:

The source of the account data is a user who opens an account. The account opening data will be used and processed for the purposes of performing a detailed Know Your Customer (Hereinafter: KYC) procedure according to necessary Anti-Money Laundering and Anti-Terrorist Regulations.

Users are visitors of the IZIBITS OÜ website and therefore their Personal Information is collected as described in the previous section. This Personal Information will be used for operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with Users.

IZIBITS OÜ will use users’ e-mail phone number and residential address for communication purposes with users regarding: login, registration, transactions, orders, safety requirements, notifications about safety measures, reminders about the status of orders, transactions, user profile level, and other necessary communication with users. The user will also receive occasional notifications about new token listing and other promotions.  

1.2. Collection of User data

During a User’s registration at IZIBITS OÜ exchange platform, Users provide information such as name, company name, email, address and nationality (registered seat of the legal entity), bank account, ID number and image of the ID document, date and place of birth, personal picture, phone number, utility bill and other relevant data.

The Users Data shall be collected and processed by a third party – Sum and Substance, LIMITED, with its registered office at Suite 1, 5 Percy Street, Fitzrovia, London, England, W1T 1DG (hereinafter Sum and Substance), who is a trusted partner of IZIBITS OÜ for collecting and processing Users data on behalf of IZIBITS OÜ. Sum and Substance is an experienced identity verification company that will process Personal Data for the purposes of the necessary KYC/AML procedures. Sum and Substance will obtain and process all the above stated Personal Data and run KYC/AML procedures and ensure compliance with the relevant AML legislation.

For the purposes of the maintaining users’ accounts and reviewing users for the purposes of KYC/AML compliance, IZIBITS OÜ will collect and process the same that Sum and Substance will collect in the process of User verification (KYC) procedure. IZIBITS OÜ will use some of those information also for personalizing Service experience, analyzing IZIBITS OÜ website usage, improve website offerings, help to respond to customers’ requests and support needs, contact you about new Services, modification of the Terms, Privacy Policy or Cookies Policy, communicate company news, updates, promotions and related information regarding the company, products or services, administering a contest, surveys, promotions and other site features.

If you wish to stop receiving marketing communications from us, please contact us at [email protected] to opt-out.

Users of IZIBITS OÜ services can at any time access and edit, update or delete their contact details by logging in with their username and password to IZIBITS OÜ platform and use “Delete User Account” setting. IZIBITS OÜ will not retain User data longer than is necessary to fulfill the purposes for which it was collected or as required by the applicable laws and regulations.

In the course of its activity, IZIBITS OÜ shall also communicate with the users via the telephone using the telephone numbers given in the identification process. Communication will serve for the purpose of verifying the credibility of the user account, thereby strengthening the platform’s security, strengthening the brand, informing users about new offers and events, about new issues of tokens and direct sales of IZIBITS OÜ services.

1.3. Geographical location of processing Personal Data

All Personal Data, which will be collected and processed within the KYC procedure by Sum and Substance and IZIBITS OÜ are stored on servers in European data regions. Such Personal Data is not transmitted to other Data Regions.

IZIBITS OÜ has servers in European data regions. A IZIBITS OÜ “Data Region” is a set of data centers located within a defined geographical area where User data is stored. Personal Data is not transmitted to other Data Regions. For IZIBITS OÜ Users, all accounts are located in IZIBITS OÜ European Data Region, all Personal Data is processed in the EEA.

It has to be noted that IZIBITS OÜ is a platform that offers buying, selling and storing virtual currencies. Trading virtual currencies take place on the blockchains (Ethereum, Bitcoin, etc.) which are decentralized databases software platforms for virtual assets. Blockchains are a list of records, called blocks, which are linked and secured using cryptography. Each block typically contains a cryptographic hash of the previous block, a timestamp and transaction data. By design, a blockchain is inherently resistant to modification of the data. Therefore Data cannot be modified or deleted, since there are no servers involved. Data are dispersed among computer all around the world in an encrypted version.

If you trade virtual currencies you agree that your Personal Data may be collected, stored, processed and that you will not be able to delete it or invoke the right to be forgotten. Your data are encrypted, meaning they are coded (anonymized). Note that also encrypted personal data that is your e.g. crypto wallet address with IZIBITS OÜ can still be traced back to a person if enough effort is put into it by experts or someone holds the key to decryption. With trading virtual assets via IZIBITS OÜ platform you expressly agree to give your Personal Data on the (public) blockchain that these Data (even though encrypted) cannot be deleted and that Personal Data may be transferred outside European territory.

You acknowledge and expressly agree that by the nature of the technology it is not possible to delete personal data from the blockchain and invoke the right to be forgotten. You also agree that by the nature of the technology it is not possible to keep personal data within the EU borders.

1.3.1. Processing in accordance with General Data Protection Regulation

The processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and our processing will take place in accordance with the GDPR.

1.3.2. Controller

IZIBITS OÜ processes Personal Data as a Controller, as defined in the Directive and the GDPR:  

IZIBITS OÜ which you as a Visitor entered an agreement with when using IZIBITS OÜ’s platform as a Visitor, will be the Controller for Visitors data, as outlined above in “Collection of Visitor data” section.

For Users data, as outlined in the “Collection of Users data” section, the IZIBITS OÜ will be the Controller in accordance with GDPR. The Users Data shall be processed by a third party Processor – Sum and Substance, to Collect and process Users data on behalf of IZIBITS OÜ. Sum and Substance is an experienced identity verification company that will process Personal Data for the purposes of the necessary KYC/AML procedures. Sum and Substance will obtain and process users: name, surname, address, residency, date and place of birth, ID number, copy ID, users’ picture, email, phone number, utility bill and other personal information. Sum and Substance is a certified ID verification company having sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of GDPR and ensure the protection of the rights of the data subject.

IZIBITS OÜ has data processing agreements in place with its providers, ensuring compliance with GDPR. All hosting is performed in accordance with the highest security regulations. All transfers of data internally is done in accordance with this data processing agreement.

IZIBITS OÜ adheres to the Directive of 1995 and the GDPR from May 25th, 2018. Consequently, IZIBITS OÜ processes all data provided by its Users with accounts in its European Data Region, in the European Union, EGS and Switzerland only.