Privacy Policy Privacy Policy
Privacy Policy

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.