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Exuprio S.r.l. Privacy Policy

This document (“Privacy Policy”) describes how Exuprio S.r.l., company registration number 12346490969 with its registered address at Via Borgogna, 8, 20122 Milano MI, Italy (hereinafter “Gainpay”, “we”, “us”, or “our”) processes personal data. Gainpay understands that your privacy is important to you and that you care about how your personal data is used and shared online. This Privacy Policy applies to personal data processing that occurs when you visit our website, www.gainpay.org (“Website”), and use our services (“Services”) or interact with us with respect to our Services.

Please read this Privacy Policy carefully and ensure that you understand it. If you have any questions regarding this Privacy Policy, feel free to contact us via the contact information stated in section 9 below.

1. Definitions and interpretation

1.1 In this Privacy Policy, the following terms shall have the following meaning:

“Account” – means an account required to access and use our Services;

“Cookie” – means a small text file placed on your computer or device when you visit certain parts of the Website and/or when you use certain features of the Website. You may read more about the Cookies we use in section 7 below;

1.2. Terms such as “personal data”, “processing”, “transfers” and other terms used in this Privacy Policy shall be construed in accordance with applicable data protection laws, i.e. the 2016/679 General Data Protection Regulation.

2. What personal data do we process?

2.1 When you sign up and create an Account

2.1.1 When you create an Account with us to use our Services, we will process the following categories of personal data:

  1. General and contact information, such as name, date of birth, e-mail address, telephone number, address and postal code, business/company name;

  2. Financial information, such as payment method information, balance information, cryptocurrency wallet addresses used;

  3. Documentation necessary for the fulfillment of Anti Money Laundering and Know Your Customer measures, such as national identity card, passport, proof of address, proof of funds & related documents;

  4. System information, such as IP address, web browser type and version, operating system, information on your Website activity, the URLs you visit from and URLs you go to once you have left our Website; and

  5. Any other information that you may share with us in a free text when you communicate with us. Please bear in mind not to share more personal data than what is necessary for the enquiry you have.

2.1.2 Please bear in mind that we are unable to provide you with the Services unless we can process the personal data listed above. The processing of the personal data listed above is necessary to enter into an agreement with us and is necessary to maintain the contractual relationship between you and Gainpay.

2.2 When you browse our Website

2.2.1 When you browse our Website without creating an Account, we will process the following categories of personal data:

  1. System information, such as IP address, web browser type and version, operating system, information on your Website activity, the URLs you visit from and URLs you go to once you have left our Website;

  2. Contact information, such as name and e-mail address when you sign up for receiving e-mails from us; and

  3. Any other information that you may share with us in free text when you communicate with us. Please bear in mind not to share more personal data than what is necessary for the enquiry you have.

3. Purposes of processing and legal grounds

3.1 When you have an Account, we will process personal data listed above for the following purposes and on the basis of the following legal grounds:

  • Providing the Services to you and managing your Account. The legal ground for this processing is contractual necessity;

  • For the fulfilment of legal obligations that Gainpay may be subject to, such as the anti-money laundering and book-keeping legislation. The legal grounds for this processing are Gainpay’s legal obligations;

  • For the enforcement of the agreement you have with us, including to protect our rights, property and safety and also the rights, property and safety of third parties if necessary. The legal ground for this is our legitimate interest to establish, exercise or defend legal claims;

  • Personalising and tailoring your experience on the Services, including gathering and anonymising data on user traffic, usage patterns, user numbers, sales and other information. The legal ground for this processing is our legitimate interest to improve our Website to make it more user-friendly;

  • Personalizing and tailoring our Services to you. The legal ground for this processing is our legitimate interest to improve our Services based on our customers’ needs.

  • Replying to your enquiries and customer service requests. The legal ground for this processing is our legitimate interest to address any questions, requests or other forms of enquiries you may have;

  • Sending you e-mails that you have opted into. The legal ground for this processing is your consent. You may withdraw your consent at any time through clicking on the “unsubscribe” link at the end of each e-mail); and

  • Market & academic research, including anonymization of statistics of the use of our Website.

3.2 When you browse our Website without having an Account, we will process personal data listed above for the following purposes and on the basis of the following legal grounds:

  • Personalising and tailoring your experience on the Website including gathering and anonymising data on user traffic, usage patterns, user numbers, sales and other information. The legal ground for this processing is our legitimate interest to improve our Website to make it more user-friendly;

  • Replying to your enquiries about us or our Services. The legal ground for this processing is our legitimate interest to address any questions, requests or other forms of enquiries you may have;

  • Sending you e-mails that you have opted into. The legal ground for this processing is your consent. You may withdraw your consent at any time through clicking on the “unsubscribe” link at the end of each e-mail); and

  • Market & academic research, including anonymization of statistics of the use of our Website.

4. How long do we store personal data for?

4.1 We do not keep your personal data for any longer than is necessary for achieving the purpose(s) for which the personal data was first collected.

4.2 Gainpay retains your personal data for the duration of providing the Services to you until you have request the deletion of your Account. Please note that once you have requested deletion, your personal data will be retained with limited access within the organization for up to 5 years due to legal statutory limits.

5. Where and with whom do we process personal data?

5.1 We may share your personal data with our affiliates and service providers in order to be able to provide our Services. These service providers may include services of payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your personal data. Where any of your personal data is required for such a purpose, we undertake steps to ensure that your personal data is processed in accordance with the requirements of the Applicable Data Protection Laws.

5.2 All of our servers are based in the European Economic Area (the “EEA”). However, we may use data processors who process personal data outside the EEA, please see the table below. In the event that a non-EEA country to which we transfer personal data has not obtained an adequacy decision from the European Union (the “EU”) Commission, we have applied safeguards for any transfers of personal data to third countries, such as the EU Commission Standard Contractual Clauses. You can obtain more information regarding the transfers of personal data by contacting us at dataprotection@gainpay.org .

  • COMPANY: GOOGLE LLC

  • LOCATION: United States of America

  • SAFEGUARD: EU Commission Standard Contractual Clauses 2010/87/EU

5.3 In certain circumstances, we may be legally required to share certain personal data we process. For example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, upon a legitimate request from a governmental authority, or to prevent and investigate fraud, or other illegal activity. This data is shared to protect ourselves, you and other customers, including where necessary for the purposes of an investigation.

5.4 We may compile statistics about the use of the Website including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personal data, or any anonymized data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers.

5.5 Please bear in mind that our Website may contain references to other websites. You may also be directed to other websites that are outside of Gainpay’s control. Hence, we recommend that you read the other websites’ privacy policies to understand the personal data processing that they conduct.

6 Security 

6.1 Data security is very important to us. Gainpay continuously undertakes appropriate technical and organisational measures to ensure adequate security of your personal data throughout the processing.

6.2 For example, we have undertaken the following steps to secure and protect your personal data:

  • We have implemented & maintain a rigorous internal data protection policy; and

  • We have server-sided security measures & firewalls.

7. Cookies

7.1 Cookie types

7.1.1 The Website places certain first party Cookies on your computer or device, as specified in section 7.3 below. First party Cookies are those placed directly by Gainpay and are used only by us. We use Cookies to facilitate and improve your experience of the Website and to provide and improve the Services. We have carefully chosen these Cookies and have taken steps to ensure that your personal data is protected and respected at all times.

7.1.2 Certain features of the Website depend on Cookies to function. These Cookies are often called strictly necessary cookies. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 7.2, but please be aware that the Website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

7.1.3 Some Cookies are designed to enable the Website to save information on your preferences in order to provide a better experience, such as to remember your username or which language you prefer to browse in. These Cookies are commonly called functionality cookies.

7.1.4 By browsing and using the Website, certain third party Cookies will be placed on your computer or device. This type of Cookies are cookies created by third parties that are placed on your computer or device via our Website. We do this for analytics – to measure and follow up on the use of our Website, as described below in 7.1.5. These Cookies are not strictly necessary for the functioning of the Website and your use and experience of the Website will not be impaired if you refuse to consent to them.

7.1.5 There are Cookies that analyse the performance of the Website and detect errors enable us to recognize whether you have visited the Website before, what pages on the Website are most visited, how much time visitors spend on our Website etc. They are commonly called performance cookies and their purpose is to improve and analyse the performance of the Website and your experience. The Website uses analytics services provided by Google LLC. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how the Website is used. This, in turn, enables us to improve the Website and the products and services offered through it. You do not have to allow us to use these Cookies.

7.2 Your consent

7.2.1 Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. The personal data processing that is conducted via Cookies is thus based on your consent as a legal ground for processing. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You have a choice to deny consent to the placement of Cookies; however certain features of the Website may not function fully or as intended.

7.2.2 In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

7.2.3 You can choose to delete Cookies on your computer or device at any time, however you may lose some information that enables you to access the Website more quickly and efficiently, such as login and personalization settings.

7.2.4 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

7.3 The Cookies set by our Website

7.3.1 The following third party Cookies will be placed on your computer or device

Preferences

  • Name: Gainpay_preferences

  • Purpose: Includes the users preferences for how certain features of the https://gainpay.org website should function, for example which language to display the content in.

  • Type: Strictly functional

  • Expiration: 1 year

Cookie consents

  • Name: Gainpay_cookie_consents

  • Purpose: Includes the users preferences for which optional cookies the https://gainpay.org website may use for additional features, for example to understand how our Website is being used.

  • Type: Strictly functional

  • Expiration: 1 year

7.3.2 The following third party Cookies will be placed on your computer or device

Mixpanel

  • Name: mp_xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx_mixpanel

  • Purpose: Collects information that is used to help us understand how our Website is being used.

  • Type: Performance

  • Expiration: 1 year

Google Analytics

  • Name: _ga

  • Purpose: Collects information that is used in aggregate form to help us understand how our Website is being used, how effective marketing campaigns are, and to help us customise our Website for you.

  • Type: Performance

  • Expiration: 2 years

8. Your rights

8.1 As a data subject, you have the following rights under the Applicable Data Protection Laws. You have the right to request access to and information about the personal data that we process about you. Additionally, you may also request that we correct (rectify), complete, erase or restrict the processing of personal data regarding you. You also have the right to request a copy of the personal data we process regarding you free of charge.

8.2 Where Gainpay processes your personal data on the legal ground of consent or fulfillment of contract, you have the right to data portability which means that you can receive the personal data in a commonly used, structured and machine-readable format and you have the right to transfer it to another controller.

8.3 You have an absolute right to object to personal data processing done for the purposes of direct marketing, such as the one described in point 3 above pertaining to your choice to receive e-mails from us.

8.4 If you have any cause for complaint about Gainpay’s processing of your personal data, please contact us using the details provided in section 9 and we will do our best to address your concerns.

8.5 If we are unable to help, you have the right to lodge a complaint with a supervisory authority, you may find your local supervisory authority by clicking here: https://edpb.europa.eu/about-edpb/board/members_en

9. Contact Us

9.1 If you want to exercise your rights as per section 8 above, or if you have any questions about Gainpay’s processing of personal data regarding you or if you have questions about this Privacy Policy, please feel free to contact our Data Protection Officer by email at dataprotection@gainpay.org or by post at

Att. Data Protection Officer
Exuprio S.r.l.,
Via Borgogna, 8, 20122 Milano MI, Italy

9.2 When you contact us, please state your full name and ensure that your query is clear, particularly in the event the query is with respect to the processing of personal data regarding you. Additionally, please note that we may have to verify your identity before we proceed with processing your request.

10. Change of control

10.1 We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business subject to a transfer, be transferred along with that part. The new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that personal data only for the same purposes for which it was originally collected by us.

10.2 In the event that any of your personal data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. However, you will be given the choice to have your personal data deleted or withheld from the new owner or controller.

11. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. Any changes will be immediately posted on the Website. We recommend that you check this page regularly to keep up-to-date. If your consent is required due to a change of this Privacy Policy, we will provide you with relevant information and ask for such consent in accordance with Applicable Data Protection Laws.