Privacy policy
ACCEPTANCE OF THE POLICY
This Privacy Policy (hereinafter referred to as the "Policy") governs the rules and principles of the process of collection, processing, storage, and transmission of Users' Personal Data by Rubicoin Software Company OÜ, registration code: 44710911, registered at Vesivarava tn 50-201, Tallinn, 10152, for the Rubicoin Application, which is available on the Android and iOS operating systems and complies with the privacy and data security standards established by these platforms.
References to the terms "we", "our", or "us" or similar words in content mean Rubicoin Software Company OÜ ("Rubicoin"), depending on the context of the Policy.
References to the terms "you", "your", or "yours" or their equivalent words in the text refer to the Users of the Application.
The main purpose of the Privacy Policy is to ensure and control the confidentiality and security of Users' Personal data, the processing of which is carried out exclusively under the terms of this Policy and international data protection and privacy legislation, which defines the lawful bases for processing, storing, and using data, as well as users' rights regarding their data.
The decision of Users to provide their Personal data for the use of the Application's services is voluntary and made at their discretion. You may refuse to provide the requested information in the Application, but such refusal may affect access to the services within the Application.
1. TERMS
Rubicoin identifies certain terms, the use of which in the Policy text indicates that they have a special meaning as defined below:
1.1
Personal data - information that identifies the User as a
specific individual or can
be
identified for your interaction with the Application.
1.2
User - an individual who interacts with the Application,
whether identifiable or not.
1.3
Application - software that includes software modules and
code owned by Rubicoin Software Company OÜ. The Application content is protected by
copyright, trademark law, and other rights related to intellectual property, as well as
unfair competition law.
1.4
EDPB - European Data Protection Board.
1.5
CCPA(California
Consumer Privacy Act) - a law of the state of California, created and
intended to enhance privacy rights and consumer protections for residents of California
and the USA.
1.6
GDPR(General Data Protection Regulation) - a
law, which regulates the processing of personal data since May 25, 2018.SA.
2. AGE RESTRICTION
2.1
The Application is intended for use by individuals who have reached the age of 18. If
you are not of legal age, you can not be a User of our Application. Rubicoin consciously
and deliberately does not collect information about individuals under the age of 18 and
believes that such individuals should obtain consent from their legal guardians before
providing any Personal data.
2.2
If you believe that Rubicoin has unintentionally and inadvertently processed and
obtained the Personal data of individuals under the age of 18, please contact us at
Ця електронна адреса захищена від спам-ботів. Вам необхідно увімкнути JavaScript, щоб побачити її. so that we can delete the Personal data of such individuals from our
resources.
3. CONSENT TO DATA PROCESSING
3.1
By providing access to Personal data you consent to their transfer, storage, and
processing. In turn, we undertake to take all necessary measures to ensure that Personal
data is processed in compliance with security rules and following the provisions of the
Policy.
4. WHAT PERSONAL DATA WE COLLECT
4.1
Rubicoin aims to limit and minimize the amount of Personal Data it collects, as well as
to provide Users with a high level of confidentiality. We do not request or process the
following categories of Personal data: first names, surnames, addresses, phone numbers,
email addresses, payment card and/or bank account information, location data, as well as
sensitive Personal data such as racial or ethnic origin, religious beliefs, sexual
orientation, political views, union membership, health information, as well as genetic
and biometric data, and information about Users' criminal records and offenses.
4.2
Automatically collected Personal data. During interactions
with the Application from your mobile device, certain information about the User is
automatically collected, such as IP address to determine the country from which you are
connecting to the Application, timezone and language settings, as well as information
about the device you are using to access the Application.
4.3
Personal data provided by the Users' initiative.
Information that you voluntarily provide during communication with our support service
through communication means is considered Personal data. This data includes user IDs
used for feedback and to provide services in the Application.
4.4
The Personal data we process and store remains the property of the Users. If changes to
Personal Data are necessary for the correct receipt of services in the Application,
Users are responsible for notifying us of such changes.
5. METHODS OF COLLECTING PERSONAL DATA
5.1
Rubicoin collects identifiable and non-identifiable Personal data of Users during their
interaction with the Application, when contacting customer support, as well as during
analytics and advertising campaigns, using advertising and analytics services such as
Google ADS, Google Analytics, Facebook ADS, and Facebook Analytics, among others. Please
note that this list is not exhaustive.
6. PURPOSES OF USING PERSONAL DATA
6.1
Rubicoin processes and has the right to use the Personal data of Users following the
purposes outlined in our Policy, namely for:
6.1.1
Providing services through the Application;
6.1.2
Developing, providing, enhancing, updating, and debugging the Application, as
well as expanding the provided services;
6.1.3
Ensuring internal quality control of services and User security, protection
against fraud or unlawful activity;
6.1.4
Processing requests, complaints, and communication with Users;
6.1.5
Ensuring compliance with laws, including the protection of our rights and the rights of third parties.
7. EMAILING AND ADVERTISING OFFERS
7.1
Rubicoin does not send out advertising messages or send Users commercial or
non-commercial offers. We also do not send
confirmations of the use of Application services or notifications about changes to this
Policy. You can view the amended
and/or updated version of the Privacy Policy within the Application.
8. DATA RETENTION PERIOD
8.1
Personal data is retained until the User’s deletion request. In the event of such a
request, Personal data will be
deleted within 30 (thirty) days from the date of receiving the request. In the absence
of a request for the deletion of
Personal data by the User, Rubicoin will retain the data for 5 (five) years from the
date of receiving the Personal data
if such retention is necessary for providing services in the Application, accounting for
statistical, analytical, and
commercial information.
8.2
Note. When receiving a request from the User for the
deletion of Personal Data and/or the deletion of the Application,
Rubicoin may retain some Personal data until necessary to comply with applicable laws,
fulfill obligations and
agreements, resolve disputes, and prevent misuse of the Application.
9. SECURITY OF DATA STORAGE AND TRANSMISSION
9.1
Rubicoin strives to make every effort to ensure that the storage of Personal data, to
the extent possible, complies with
GDPR and CCPA legislative acts. Rubicoin takes measures to ensure the security of
storing Personal data, such as
anonymization and encryption, ensuring the confidentiality, integrity, availability, and
resilience of processing
services, and testing the effectiveness of protective measures, under Article 32 of the
GDPR.
9.2
We implement secure measures for obtaining and storing collected Personal Data of Users
on servers and hosting, namely:
9.2.1
Implementing AES 256 SIV algorithms for key encryption and AES256 GCM for data
encryption, ensuring a high level of data
security;
9.2.2
SHA256 hashing algorithm, which helps ensure data integrity and uniqueness;
9.2.3
Anonymizing Users’ data to make it impossible to identify a specific User;
9.2.4
Encrypting access to the Application using the TLS protocol, which is designed
to protect against data interception
during transmission and ensure secure data transmission over the internet;
9.2.5
Using the HTTPS protocol, which provides transport security for data
transmission between the User and the server
9.3
While observing the necessary security measures for data collection and storage,
Rubicoin cannot guarantee absolute
protection against potential access, disclosure, alteration, or deletion of data in the
event of various events,
including but not limited to hardware or software failures or unauthorized use. Rubicoin
is not responsible for
instances of leakage, unauthorized collection and disclosure, resale, and misuse of
Users' Personal data by third
parties
10. DATA PROTECTION OFFICER
10.1
To enhance control over data storage and security, Rubicoin may appoint a Data Protection Officer (hereinafter - "DPO"),
who is responsible for compliance with data protection laws, following
Articles 37,
38,
and 39 of the GDPR,
specifically to perform the following tasks:
10.1.1
Informing the controller and processor about obligations according to the data
protection regulation;
10.1.2
Monitoring compliance with the requirements of the regulation;
10.1.3
Representing the company in supervisory authorities for compliance with the regulation;
10.1.4
Consulting in any situations affecting the regulation;
10.1.5
Receiving and processing complaints and inquiries from Users to protect their rights,
under Section 11 of the Policy.
11. INTERNATIONAL TRANSFER OF PERSONAL DATA
11.1
Transfer of personal data to third parties. Rubicoin appreciates and maintains the
confidentiality of Users’ data,
therefore we do not sell Users' Personal data to third parties. However, to provide
services
in the Application, we may
transfer Personal data to our service providers or third parties whose services are
integrated into the Application.
Such service providers and/or third parties have access only to the information
necessary
for integrating services into
the Application.
11.2
Transfer of anonymized information. Rubicoin may share anonymized information with third
parties such as publishers,
advertisers, developers, or rights holders, without the ability to identify individuals
and
personalize Users.
11.3
Transfer upon change of business ownership. If Rubicoin buys or sells a business,
information about Users may be
transferred as part of the business assets. This information will be protected by our
privacy terms and applicable data
protection laws.
12. INTEGRATED THIRD PARTY SERVICES
12.1
To provide services to Users, Rubicoin may integrate third party services into the
Application. In some cases, these
third parties may process and collect the Personal data of Application Users. Users’
data
transmitted to third parties
is governed by the Policies and Terms of Use of such third parties. Links to the
documents
are provided in the
Application. By agreeing to this Policy, Users grant the right to process and collect
their
Personal data by third
parties.
12.2
Rubicoin does not control third parties services that may be hosted in the Application.
Such
services may request
Personal data from Users, place cookies on Users' devices and/or use other methods to
collect data. Before using third
party services hosted in the Application, it is recommended to review their Privacy
Policy.
12.3
Mercuryo. The Application integrates services provided by
Mercuryo (https://mercuryo.io/), which may conduct Know Your
Customer (KYC) procedures and process and collect Users’ Personal data. By using
Mercuryo
services through the Rubicoin
Application, Users agree that Mercuryo will collect and process their Personal data
under
Mercuryo's Privacy Policy
(https://mercuryo.io/legal/privacy/).
Rubicoin is not responsible for the collection, use, and processing of Users'
Personal data by Mercuryo, nor does it process or have access to the Personal data of
Users
collected and processed by
Mercuryo. Users are required to review Mercuryo's Privacy Policy before using its
services
through the Rubicoin
Application. Users also understand and agree that Rubicoin may transfer certain Personal
data of Users to Mercuryo to
comply with legal requirements and ensure system security and integrity.
12.4
The integration of third party services into the Application does not imply any
connection
between Rubicoin and them,
nor does it imply that their Privacy Policy complies with Rubicoin's Privacy Policy.
13. USER RIGHTS
13.1
According to the General Data Protection Regulation (GDPR), Users have certain rights
regarding the Personal Data they
provide to Rubicoin for the use of services in the Application, namely, the User has the
right to:
13.2
Request access to information. The User may contact us via
email at Ця електронна адреса захищена від спам-ботів. Вам необхідно увімкнути JavaScript, щоб побачити її. to request access to the
Personal Data we process and store, following Article 15 of the General Data
Protection
Regulation. In such a case, we
will provide a copy of the data we store.
13.3
Rectify data. The User has the right to rectify and/or
update their Personal data. To do this, you can contact us via
email at Ця електронна адреса захищена від спам-ботів. Вам необхідно увімкнути JavaScript, щоб побачити її. so that we can correct or update your data and notify you
of such correction, following
Article 16 of the General Data
Protection Regulation.
13.4
Request data portability. The User may request the transfer
of
Personal data to a third party, following 20 of the General Data Protection
Regulation
In such a case, we may charge you an administrative fee.
13.5
Withdraw consent for data processing.
Users have the right to withdraw their consent for the processing of Personal data
provided to Rubicoin at any time,
following Article 21 of the General Data
Protection Regulation. In the event of withdrawal of consent for processing,
some Application services will become unavailable to you
13.6
Request data erasure.
The User has the right to request Rubicoin to delete their data following Article 17 of the General Data Protection
Regulation. To delete data, you need to contact us via email at Ця електронна адреса захищена від спам-ботів. Вам необхідно увімкнути JavaScript, щоб побачити її.. In the case of a deletion request,
Personal data will be deleted within 90 (ninety) days from the date of receiving the request. Some information about
you, such as your wallet address, cannot be deleted from the blockchain, so we will not be able to delete such data. In
addition, some rights may be restricted, for example, if deleting your information would lead to the disclosure of
Personal data of another User or if we are required to retain information by law or for fraud prevention purposes.
13.7
Your Personal data may remain in our archives, and the information you add or delete may be retained for our
administrative purposes under the law. Rubicoin does not delete information that you have posted publicly through the
Application. Also, please note that neither Users nor Rubicoin can delete all copies of information that have been
previously shared with other parties.
14. CALIFORNIA RESIDENT PRIVACY NOTICE
14.1
This additional privacy notice is exclusively for residents of California, aimed at
providing greater control over data
and applies to the Personal data that Rubicoin collects and processes in the
Application.
14.2
Upon request from a California resident, Rubicoin will provide information about the
categories of Personal data,
sources of data collection, the purposes for which this information was collected, and
the categories of third parties
to which we disclose Personal data of California residents. CCPA permits you to:
14.2.1
Request access to Personal data and categories of such data collected by
Rubicoin in the last 12 (twelve) months from
the date of the request;
14.2.2
Request deletion of Personal data stored by Rubicoin;
14.2.3
Request disclosure of the purpose for collecting or processing your Personal
data;
14.2.4
Opt-out of the sale of your data to third parties and/or specific categories of
third parties;
14.2.5
Request access and/or information about the data Rubicoin holds regarding you.
15. PRIVACY POLICY UPDATE
15.1
We reserve the right to periodically update and make changes to the Rubicoin Privacy
Policy to improve the security
measures for processing and storing Users' Personal data and to comply with GDPR/CCPA
legislation. Any updates to the
Policy will be published within the Application. Notifications of such changes will not
be sent to Users via email or
through in-app notifications.
15.2
By continuing to use the Application after changes have been made to the Privacy Policy,
you automatically agree to the
updated version of the Policy.
15.3
The Privacy Policy stored in our systems and published on our resources is considered
current, complete, and obligatory
for compliance when Users use the Rubicoin Application.
16. APP REVIEWS
16.1
Rubicoin collects reviews and recommendations about the Application to effectively
promote and improve our services.
Such information helps us respond to User requests, improve the operation of the
Application, and develop and update new
products and features that may be useful to our Users.
16.2
We adhere to principles of confidentiality and do not publish reviews and
recommendations without your consent. However,
if you agree, we may publish your review that includes your Personal data or a reference
to your profile. If you need to
update or delete your review, please contact us at: Ця електронна адреса захищена від спам-ботів. Вам необхідно увімкнути JavaScript, щоб побачити її.
17. CONTACTING USER SUPPORT
17.1
To resolve any issues related to the collection and processing of your Personal data,
you can contact Rubicoin user
support at the email address: Ця електронна адреса захищена від спам-ботів. Вам необхідно увімкнути JavaScript, щоб побачити її.
17.2
You can also request additional information about your rights regarding your Personal
data by contacting Rubicoin user
support at the email address: Ця електронна адреса захищена від спам-ботів. Вам необхідно увімкнути JavaScript, щоб побачити її.
17.3
If you encounter privacy issues or have questions or complaints regarding the
Application and/or our Privacy Policy, you
can contact Rubicoin user support at the email address: Ця електронна адреса захищена від спам-ботів. Вам необхідно увімкнути JavaScript, щоб побачити її.
18. CONTACTS
18.1
Rubicoin Software Company OÜ
18.2
Vesivarava tn 50-201
18.3
Tallinn
18.4
10152
18.5
Ця електронна адреса захищена від спам-ботів. Вам необхідно увімкнути JavaScript, щоб побачити її.