Last updated: April 25, 2023
We at SingleBroker GmbH, a private company registered under the laws and regulations of Switzerland (SingleBroker, Company or We), respect and value your (user or you) privacy and does all possible to ensure the safety of Your Personal Data (as defined below).
This Privacy Policy (Policy) provides information on the extent of the Personal Data collected, explains the purposes for its collection and ways we use it, and identifies third parties with whom your Personal Data is shared.
This Policy is integral to the Terms and Conditions published at https://www.singlebroker.com/terms-and-conditions
Please carefully study this Policy before sharing your Personal Data with us, and contact us if you have any questions.
IF YOU DO NOT AGREE WITH ANY PROVISION OF ALL OF THIS POLICY, THEN YOU SHOULD NOT SHARE WITH US ANY PEACE OF YOUR PERSONAL DATA OR REGISTER ON THE SITE, AND YOU MUST DELETE YOUR ACCOUNT (IF APPLICABLE) AND DISCONTINUE THE USE OF THE SITE IMMEDIATELY.
These Terms may be modified, changed, or updated by us occasionally. Any amendments to these Terms will be identified through uploading a new version with a modified date of the last update on the first page or otherwise communicated to you following applicable law.
For any matters, feel free to contact us as follows:
- by phone at +41 41 55 100 53
- through email at hello@singlebroker.com
- by post to Mühlegasse 18, CH-6340 Baar, Switzerland.
1. THE TERMS
1.1. This section defines the terms used herein. Any other terms used but not specified in this section should be interpreted in the way they are interpreted in the annexes and the Site.
1.2. If no interpretation of any term is given in this Policy, Annexes, and the Site, it should be understood according to the applicable laws and regulations or general practice.
“SingleBroker” / “We” / “Company” - SingleBroker GmbH, a private company incorporated under the laws of Switzerland with a reference number CH-170.4.018.420-0 addressed at CH-6340 Baar, Mühlegasse 18, Canton of Zug, Switzerland.
“User” / “You” - a natural person or legal entity accepted these Terms, registered an Account, and used the Site.
“Site” - a cumulative set of source code, information, data, products, materials, services, web forms, hardware and software, APIs, design elements, text, images, photographs, illustrations, audio and video contents, artwork, graphics, and other intellectual property objects that can be accessed from various user’s devices connected to the Internet using special software for viewing web pages (browser) under the domain name: “singlebroker.com”, including all subdomains, the exclusive rights and(or) the right to use which belong to SingleBroker.
“Personal Data” - any information that relates to an identified or identifiable living individual that users provide us during Account registration, information that is collected about you automatically by the Site system, the information you shared with us for verification and communication purposes, as well as information that we obtain from third parties.
“Account” - an account created by you on the Site to use our Software Services, which provides data on the executed and executing Instructions, information on the user's Digital Asset balance on his/her/its wallets opened with Third-Party Providers, details of the Digital Assets market situation and other information concerning the Digital Assets.
“Personal Data Processing” - a wide range of operations performed on Personal Data, including by manual or automated means the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.
1.3. In this Policy, a reference to a policy or document is a reference to that policy or document as modified or replaced occasionally. While a reference to a clause or schedule, unless the context requires otherwise, is a reference to a clause of or schedule to this Policy.
1.4. The headings in this Policy are for convenience only and do not affect the meaning or interpretation of any provision of the Policy.
2. POLICY ACCEPTANCE
2.1. Where you agree to all and any of the Policy provisions, you can accept it by placing ☑ next to the box “I have read and accept the terms of the Privacy Policy” and pushing the “SIGN UP” button during the registration of your Account.
2.2. IN CASE YOU AT ANY POINT DO NOT AGREE WITH ANY PROVISION OF THIS POLICY, YOU SHALL IMMEDIATELY STOP THE PROCESS OF REGISTRATION AND CEASE ANY FURTHER USE OF THE SITE.
3. PERSONAL DATA COLLECTED
3.1. During your use of the Site and Software Services, we may collect the following types of Personal Data:
Communication Data:
- Your email address;
- Other contact details that you use to contact us.
Registration Data:
- Your first and last name;
- Your email address.
Automatically Collected Data:
- Technical information:
--- The internet protocol (IP) address;
--- Browser type and version;
--- Time zone setting;
--- Browser plug-in types and versions;
--- Operating system and platform.
- Usage Data:
--- Uniform Resource Locators (URL) clickstream to, through, and from the Site (including date and time);
--- Products Users viewed or searched for;
--- Page response times;
--- Download errors;
--- Time of visits to certain pages;
--- Click-stream data;
--- Methods used to browse away from the page;
--- other data collected via cookies and similar technologies.
Enhanced Verification Data:
Data provided by you upon our request where you fall under the conditions of conducting enhanced verification as a condition of your access to all our Software Services. Such data may include any of the following:
- Government-issued identity documents such as Passports;
- National Identity Card;
- Driver's License;
- Utility bill;
- any other information necessary to comply with legal obligations under financial or anti-money laundering laws.
3.2. We are constantly developing the Site and may add new features to get access to which you may be requested to provide additional information (Personal Data).
3.3. You provide us with any Personal Data voluntarily. However, where you elect not to share with us your Personal Data, we may not be able to serve you as effectively and(or) liable your access to the Site system and functionalities.
4. COLLECTING PURPOSES
4.1. We collect the aforementioned Personal Data for the following purposes:
Communication Data:
- To provide you with the requested feedback;
- To contact you for administrative reasons.
Registration Data:
- To provide access to the Site;
- To ensure network and information security;
- To provide user support.
Automatically Collected Data:
- To ensure network and information security;
- To ensure the normal functioning of the Site system;
- To enhance your user experience;
- To indicate the errors and weak points of the Site and develop it;
- For other purposes set out in the Policy.
Enhanced Verification Data:
To conduct enhanced AML/KYC verification as we may be required by the applicable law and ensure the Site's safety.
4.2. We will only use your Personal Data for the stated purposes of its collection. The only two exemptions to this rule are the situations where (a) we reasonably consider that your Personal Data is required to be used for another reason, which is compatible with the original purpose, or (b) we are obliged to process your Personal Data by applicable laws or court/enforceable orders.
4.3. Where we need to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
5. WAY WE COLLECT PERSONAL DATA
5.1. We collect Personal Data from users in a variety of following ways:
Communication Data. We get access to such Personal Data when you reach us for any questions before your Account is registered to get customer service or for any other purposes (e.g., by email).
Registration Data. You provide us with such Personal Data when you fill in and submit relevant application forms and complete the required steps to register the Account.
Automatically Collected Data. When you interact with the Site, we may collect this Personal Data using cookies, server logs, and other similar technologies.
Enhanced Verification Data. We receive such Personal Data directly from you and obtain it from other sources based on our Personal Data.
6. RETENTION PERIOD
6.1. We will keep your Personal Data for no longer than necessary to fulfill its collection's purpose.
6.2. Generally, we will retain and delete Your Personal Data as follows:
Communication Data. We will keep it until the moment we provide you with feedback.
Registration Data. We keep it strictly throughout the life of your Account and delete it once the Site system executes the request to delete your Account. Where required by applicable law, Personal Data may be retained after the Account is deleted, but only for the period prescribed by the law.
Automatically Collected Data. We keep it strictly throughout the life of your Account and delete it once the Site system executes the request to delete your Account. Where required by applicable law, Personal Data may be retained after the Account is deleted, but only for the period prescribed by the law.
Enhanced Verification Data. We keep it strictly throughout the life of your Account and delete it once the Site system executes the request to delete your Account, but, in any case, not less than necessary to achieve the processing objectives. Where applicable law requires, Personal Data may be retained after the Account is closed within the period prescribed by such laws.
6.3. Please note that we can keep your Personal Data for a more extended period where the relevant laws and regulations require it. The Company retains some of the Personal Data after the closure of your Account to deter fraud by ensuring that persons who try to commit fraud cannot avoid detection simply by deleting their Account and opening a new account, and complying with our legal obligations.
7. LEGAL BASIS FOR PROCESSING
7.1. The processing of Personal Data is performed following privacy rights and regulations foreseen by the following acts and documents:
(a) Swiss Federal Data Protection Act (FADP);
(b) EU General Data Protection Regulation - Regulation (EU) 2016/679 (GDPR);
(c) Terms; and
(d) Our internal regulations.
7.2. Where regulations of the country of your location provide for stricter Personal Data standards, the processing of your Personal Data will be effectuated following these standards.
7.3. Generally, the legally prescribed basis for Personal Data Processing includes the following:
Your Consent. You grant us consent for processing your Personal Data for specific purposes when you register an Account; the lawfulness of such processing is based on your consent. Providing us consent for the processing of Personal Data is voluntary. Any consent granted may be revoked at any time. Please be advised that the revocation shall only have effect in the future. Any processing carried out before the revocation shall not be affected.
Agreement Performance. It means processing your Personal Data where it is required to perform an agreement to which you are a party or to take steps at your request before agreeing. This includes the Terms.
Our Legitimate Interest. It means our interest to conduct and manage our business affairs appropriately and responsibly, to protect the reputation of our business, and to provide you with the best possible Software Services and secure experience.
Legal Compliance. We process your Personal Data where necessary for compliance with a legal or regulatory obligation.
8. PERSONAL DATA SHARING
8.1. Sometimes we need to share Personal Data with third parties. Please find below the list of the limited third parties with whom we may share your Personal Data:
Courts and(or) authorities and(or) law enforcement officials. We will only use and share Your Personal Data where it is necessary to lawfully carry out our business activities, in other words, where applicable laws and regulations require it.
Analytics and search engine providers. We provide them with such information to improve and optimize the Site, but we can guarantee that we will not sell, exchange, or share your Personal Data with any third parties without your express consent.
9. PERSONAL DATA EXPORT
9.1. To facilitate our global operations, we may use the services of overseas data processing service providers unless your jurisdiction's laws and regulations limit such data transfer.
9.2. We hereby warrant that we will only transfer your Personal Data to countries deemed to provide adequate protection for Personal Data compared to the FADP and the GDPR. We will make all possible efforts to ensure the protection of your Personal Data following this Privacy Policy wherever your Personal Data is processed. We will take appropriate contractual or other steps to protect the relevant Personal Data following applicable laws.
9.3. Where such service providers are not established in a country ensuring an adequate level of protection within the meaning of the FADP and the GDPR, such as the United States, the transfers will be covered by the standard data protection clauses as adopted by the FADP and the GDPR or by another appropriate safeguard mechanism.
10. PERSONAL DATA PROTECTION MEASURES
10.1. We have implemented several technical, organizational, and administrative measures to ensure the confidentiality, integrity, availability, and privacy of your Personal Data and to protect it from loss, theft, unauthorized access, misuse, alteration, or destruction, which are generally accepted by the industry to protect the Personal Data in its possession.
10.2. These measures include but are not limited to implementing security technologies: Secure Sockets Layered (SSL) technology to ensure that your Personal Data is fully encrypted and sent across the Internet securely, secure coding principles, and regular penetration testing.
10.3. We also use encryption (HTTPS/TLS) to protect data transmitted to and from the Site. Transport Layer Security (TLS) is a protocol that provides privacy and data integrity between two communicating applications. It's the most widely deployed security protocol used today and is used for Web browsers and other applications that require data to be securely exchanged over a network, such as file transfers, VPN connections, instant messaging, and voice-over IP.
10.4. Only authorized personnel have access to the Personal Data, and these personnel are required to treat the Personal Data as confidential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.
If you become aware of any potential data breach or security vulnerability, you are requested to contact us immediately. As required, we will use all measures to investigate the incident, including preventive measures.
11. YOUR RIGHTS
11.1. Your principal rights as the Personal Data subject include the following:
(a) Right, to access Personal Data.
You may request us to provide you with a copy of your Personal Data that we can access. We will provide you with such information within a reasonable period and may require you to compensate for the expenses associated with gathering the information.
(b) Right to Personal Data rectification.
You may request to rectify or update any of your Personal Data. You can do this using relevant Site functionality or by contacting us directly. We hereby reserve the right to reject personal assistance where rectification of Personal Data is available through the Site functionality.
(c) Right to Personal Data deletion.
You may request to erase your Personal Data, subject to applicable law. Please note that in some cases, the Site will automatically delete your Personal Data when you delete your Account. However, if you delete the Account, we will not use your Personal Data for any further purposes, nor share it with third parties, except as required by the law. Please note that we may not always be able to comply with your request for erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
(d) Right, to withdraw consent.
To the extent the processing of your Personal Data is based only on your consent, you may withdraw your consent at any time. It will not affect the lawfulness of any processing carried out before the withdrawal. Please note that any processing activities not based on your consent will remain unaffected.
(e) Right to restrict processing.
In some jurisdictions, applicable law may give you the right to restrict or object to our processing or transferring of your Personal Data under certain circumstances. We may continue to process your Personal Data if necessary to defend legal claims or any other exceptions permitted by applicable law.
11.2. Kindly note that none of the rights is absolute, meaning that they must generally be weighed against our own legal obligations and legitimate interests. If a decision is taken to override your request, you will be informed of this by us, along with the reasons for our decision.
11.3. To exercise such rights, you may contact us at the email address provided at the end of this document.
12. LINKS TO THIRD-PARTY WEBSITES/PLATFORMS
12.1. The Site may contain links to external websites/platforms maintained by third parties whose Personal Data and privacy practices are different from ours.
12.2. We are not responsible or liable for the Personal Data or privacy practices employed by such third parties. We strongly recommend you read the privacy statements of all third-party websites before using such websites or submitting any Personal Data or any other information on or through such websites.
12.3. Using our Software Services, you acknowledge and agree that the underlying protocols are subject to sudden changes in operating rules, known as Forks. In the event of Fork, you agree that we may suspend SingleBroker’s operations (with or without advance notice to you) and that SingleBroker may, in its sole discretion, decide whether or not to support (or cease supporting) either branch of the forked protocol entirely. You acknowledge and agree that SingleBroker assumes no responsibility or liability regarding an unsupported branch of a forked protocol.
13. COOKIES
13.1. What are “cookies”? Cookies are small text files that are stored on your device when you visit the Site. These text files store certain information, such as your language preference. When you visit the Site again, this file is sent to the Site. In this way, the Site recognizes your browser and can, for example, remember your language preferences.
13.2. How long do cookies stay on your device? Cookies usually have an “expiration date," which indicates how long they are stored on your device. Some cookies are automatically deleted when you close the browser (session cookies), while others remain on your device for a longer period, sometimes until you manually delete them (permanent cookies).
13.3. Why do We use cookies? We use three types of cookies:
- Functional cookies;
- Analytical and operational cookies;
- Communication and marketing cookies.
Functional cookies: are necessary for the normal functioning of the Site. The Company uses such cookies to authenticate users or enable the normal operation of certain Site functions.
Analytical and operational cookies: we may use cookies to recognize repeat visits to the Site by users, the type of content viewed on the Site and the links to other partners' sites from the Site, the time of opening each section of the Site, as well as the use of certain functionality of the Site.
We use Google Analytics for analytical purposes. When the user moves between web pages, Google Analytics provides website owners with specific JavaScript tags (libraries) to record information about the page the user viewed, such as the URL of the page (for more information, see Google Analytics' website privacy overview). Google Analytics use of cookies on websites and(or) see the Google Privacy and Data Protection Overview for more information about the data collected by Google Analytics).
In addition, we receive certain information during sessions conducted through your browser to access our Site and other content provided by or on behalf of the Company on other websites or when reading emails. Collecting this information allows us to better understand our users, identify the resource through which the Site is accessed, and learn how Users use the Site.
We use this information for analytical purposes and to improve the Site. Such information includes:
- Technical information, including the Internet Protocol (IP) address used by Your computer or device to access the Internet, browser type and version, time zone settings, plug-in types and versions, and operating system platform;
- Information about Your visit or opening an email, including the Uniform Resource Locator (URL), history of links to or from our Site or exits (including date and time of visit); page response time, load failures, duration of visits to certain pages, page usage information (such as scrolling, clicking or hovering), and how you exit the Site page.
13.4. How do I know which cookies have been placed on my device, and how do I delete them? If You wish to find out which cookies are installed on your device or wish to delete them, you may use your browser settings. Please note when you delete or refuse the use of cookies, You agree that you may lose access to some features of the Site.
You can block your browser from accepting certain cookies, require your browser's consent before a new cookie is placed in your browser, or block cookies altogether by selecting the appropriate setting in your browser's privacy settings menu. To disable cookies in the browser of your mobile device, you need to refer to its respective user manual.
Most web browsers allow you to view and delete cookies through your browser settings. To learn more about cookies, including what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
14. AMENDMENT
14.1. The Company hereby reserves the right to amend this Policy by publishing its updated version on the Site with a new date of the last update on its first page.
14.2. You acknowledge that your continued use of the Site after we published an updated version of the Policy shall be recognized as your unconditional and unequivocal consent to all of the provisions of the updated Policy.
14.3. You hereby undertake regularly to check the published version of the Policy for amendments and to familiarize yourself with the amended text (if the Policy is amended).
14.4. We are not obliged to notify you about amendments to the Policy.
15. CONTACT US
For any information and questions regarding the Policy, you can contact us as follows:
- by phone at +41 41 55 100 53
- through email at hello@singlebroker.com
- by post to Mühlegasse 18, CH-6340 Baar, Switzerland.
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