PRIVACY NOTICE


Who are we?


BLINKIO OÜ is a company registered in Estonia (registry code 14718623), that operates an online cryptocurrency exchange (crypto to fiat) called Bitcoinblink, with the appropriate licenses issued by the European Union. 

BBlinkio OÜ via its platform “BitcoinBlink” allows its users (individual or corporate) to buy and sell cryptocurrencies for traditional currencies such as the Euro/Dollar.


Virtual Currency Wallet Service FRK000807

Exchange of cryptocurrency to Fiat Currency FVR000913



Contact details of BBlinkio OÜ:


Name: BBLINKIO OÜ

Number: 14718623

Address: Harju maakond, Tallinn, Kesklinna linnaosa, Pärnu mnt 41a-304, 10119

Manager: Iseki Solari

E-mail: [email protected]

Telephone: +372 5331 2517

Internet site: https://www.bitcoinblink.com


Contact details of the Data Protection Officer (Responsible person for GDPR matters):


Name: Dimitar Kolchakov

E-mail: [email protected]


Your personal data that we process are:


Personal data category:


  • Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, email, tax ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information;


  • Bank account information, payment card primary account number, transaction history, information about the transactions you make on our services, such as the name of the recipient, your name, the amount


  • Geo location/tracking details, browser fingerprint, OS, browser name and version, personal IP addresses;


The Personal Data collected by BBlinkio OÜ is required for BBlinkio OÜ's services to function and be delivered to BBlinkio OÜ's users and customers, as well as to enable prompt communication in case of security concerns, unusual events, technical failures or other legitimate interest of BBlinkio OU's customers.


Users' name and employment information are required in order to ensure auditability of BBlinkio OU's systems by its customers and help to prevent fraud. They are also necessary in order to ensure the correct level of access to BBlinkio OÜ's customers' information by BBlinkio OÜ's users.


Users' contact means (email, telephone, and others) are used for purposes which may include Customer Support, the enabling of notifications that users themselves or others within their organization can configure to be triggered in specific events, and other automatic notifications to alert users in case of system failures, security concerns or unusual events.


Activity and Usage Data of BBlinkio OÜ's users, which may include:


  • Information about interactions with the BBlinkio OÜ's services, including the date and time of any request made by devices operated by the user


  • The configuration settings with which the user is accessing BBlinkio OÜ's services, for example, language


  • Information about records that have been created, modified, accessed or destroyed by the user, including the date and time of such operations


  • The list and sequence of elements of BBlinkio OÜ 's interface that the user has interacted with, including the date and time of the interaction


  • The amount of data transferred to and from BBlinkio OÜ's services as a result of the user's activity


  • Interactions with BBlinkio OÜ's Customer Service, including their date and time, messages and contact information the user included as part of the communication


  • Technical Data which may include URL information, cookie data, IP address, the types of devices the user is operating to access or connect to BBlinkio OÜ's services, their unique device IDs and attributes, network connection information including connection type and provider, network and device performance, browser type, device language, device manufacturer, model and operating system



Activity and Usage Data can be stored in various forms, which may include system logs, internal databases, and third-party web analytics tools.


Activity and Usage Data is used for various purposes which may include billing of BBlinkio OÜ's services, rendering of services to the user and to BBlinkio OÜ's customers, as well as service improvement activities.


The amount of data transferred to and from BBlinkio OÜ's systems as a result of users' activity is used for calculating volume-based fees billed to BBlinkio OÜ's business customers; user activity logging is required in order to safeguard the right to auditability of BBlinkio OÜ's systems by BBlinkio OÜ's customers and help to prevent fraud; data about users' usage of BBlinkio OÜ's services are used to troubleshoot problems and identify usage patterns with the purpose of enabling product development, delivering better customer support and continuously improving BBlinkio OÜ's product and services.


Тhe personal data we collect will only be used for the following purposes:


BBlinkio OÜ offers digital services to business customers with which commercial agreements exist. BBlinkio OÜ 's users are primarily employees of BBlinkio OÜ 's customers or other data subjects otherwise authorized by BBlinkio OÜ's customers to access and use BBlinkio OÜ's services.


BBlinkio OÜ collects, processes and stores personal data about its users. The purposes of such data may include the correct functioning and delivery of BBlinkio OÜ's services, the compliance with this privacy policy or with other agreements that are in place between BBlinkio OÜ and its customers, the safeguarding of the right to auditability by BBlinkio OÜ's customers of BBlinkio OÜ's systems and the accrual of usage-based fees billed by BBlinkio OÜ to its customers.


BBlinkio OÜ must identify and verify customers in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. We process your personal information in order to provide our services to you.


Based on your direct marketing preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing, and to provide you with promotional offers based on your communication preferences. You can opt-out of our marketing communications at any time.


We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission.


The basis that entitles us to process your data is:


- Law requirements

- Customer consent

- Customer agreement


The following organizations/individuals will receive your personal data:


- State institutions

- Other Controller/Processor with GDPR contract with us.

- Marketing companies (optional)


Data storage period:


BBlinkio OÜ will store your personal data of legally set deadlines


Your rights as a data subject are as follows:


  • At any time while we store or process your personal data, you have the following rights:


  • you have the right to request a copy of your personal data to the BBlinkio OU and the right of access at any time to your personal data;


  • you have the right to request your personal data in a form convenient to transfer to another personal data administrator from BBlinkio OÜ or to ask us to do so without being hindered by ourselves;


  • you have the right to ask BBlinkio OÜ to correct without undue delay your inaccurate personal data as well as the data that is not up to date;


  • you have the right to request from BBlinkio OÜ that your personal data be deleted without undue delay in any of the following circumstances: 


- personal data are no longer needed for the purposes for which they were collected;

- when you have withdrawn your consent;

- when you have objected to the processing,

- when processing is unlawful;

- where personal data must be erased in order to comply with a legal obligation under EU law or the law of a Member State that applies to us as a data BBlinkio OÜ;

- when personal data have been gathered in connection with the provision of information society services.


We may refuse to delete your personal information for the following reasons:


  • in the exercise of the right to freedom of expression and the right to information;
  • to comply with a legal obligation on our part or to carry out a task in the public interest,
  • in the exercise of the official powers granted to us (in case you are a body of authority);
  • for reasons of public interest in the field of public health;
  • for purposes of archiving in the public interest, for scientific or historical research or for statistical purposes, in so far as deletion is likely to render impossible or seriously obstructing the achievement of the purposes of such processing; or for the establishment, exercise or protection of legal claims.


You have the right to request from BBlinkio OÜ to restrict the processing of your personal data, in which case the data will only be stored but not processed. Our refusal to restrict will be explicit only in writing, and we are obliged to motivate it for the legitimate reason;


  • You have the right to withdraw your consent to the processing of your personal data at any time with a separate request addressed to the administrator;
  • You have the right to object to certain types of processing, such as direct marketing (unsolicited advertising messages);
  • You have the right to object to automated processing, including profiling;
  • You have the right not to be the subject of a decision based solely on automated processing including profiling;
  • If we need to use your personal data for a new purpose not covered by this data protection statement, we will provide you with a new data protection skill and when and where necessary we will require your prior consent for the new processing.


All the above requests will be forwarded if there is a third party (recipients, including outside the EU and international organizations) in the processing of your personal data.



You have the right to complain to the supervisory authority


In case you wish to file a complaint about the processing of your personal data through BBlinkio OÜ(recipients, including outside the EU and international organizations), you can do so by contacting BBlinkio OÜ or directly of the Data Protection Officer.





PRIVACY POLICY

BBlinkio OÜ




I.     General provisions and definitions



1. BBLINKIO OÜ is a company registered in Estonia (registry code 14718623), that operates an online crypto currency exchange (crypto to fiat) called Bitcoinblink, with the appropriate licenses issued by the European Union. BBlinkio OÜ via its platform “BitcoinBlink” allows its users (individual or corporate) to buy and sell cryptocurrencies for traditional currencies such as the Euro/Dollar.


- Virtual Currency Wallet Service FRK000807

- Exchange of cryptocurrency to Fiat Currency FVR000913


The Privacy policy of BBlinkio OÜ is based on the personal data protection requirements and principles adopted by virtue of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (Regulation (EU) 2016/679 or General Data Protection Regulation). 

This document is also in compliance with world legislation requirements and best practice in data privacy.


BBlinkio OÜ has appointed a Data Protection Officer (DPO), Dimitar Hadzikocev, having the following address str.72, Sofia 1000, Bulgaria (EU), e-mail: [email protected], telephone number: +359878562211. 

The DPO meets the requirements of the General Data Protection Regulation.


2. The terms listed below have the meanings assigned to them in the Regulation (EU) 2016/679 (General Data Protection Regulation) and the accompanying Policy:


Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Controller means any natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or the other applicable law.

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Data subject is an identified or identifiable natural person who can be identified, directly or indirectly, based on particular information representing personal data;


3. BBlinkio OÜ acknowledges the privacy of natural persons and makes efforts to protect them against any unlawful processing of their personal data. 

BBlinkio OÜ applies the relevant technical and organisational measures to protect the personal data of natural persons in accordance with the effective legislation.


II.    Processing of personal data


4. BBlinkio OÜ, in its capacity as controller/processor of personal data, processes personal data in a manner that ensures appropriate level of security, including protection against unauthorised or illegal processing and against accidental loss, destruction or damage, while applying suitable technical and / or organisational measures in compliance with the following principles:

(a) lawfully, fairly and in a transparent manner in relation to the data subject ("lawfulness, fairness and transparency")


(b) data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes ("appropriateness in the processing of personal data and purpose limitation")


(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ("data minimisation")


(d) accurate and kept up to date


(e) limitation of the storage for periods not longer than necessary for the purposes for which they are processed ("storage limitation")


(e) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures ("integrity and confidentiality").


5. BBlinkio OÜ processes personal data only if and to the extent of at least one of the conditions listed below applies:


(a) Processing is required for the performance of an agreement with BBlinkio OÜ under which the data subject is party or to undertake steps at the request of the data subject prior to the signing of an agreement with BBlinkio OÜ.


(b) Processing is required for compliance with a legal obligation which applies to BBlinkio OÜ in its capacity as controller/processor of personal data.


(c) the data subject has given consent for the processing of their personal data for one or more specific purposes. In the cases when personal data are processed solely on the grounds of consent, the data subject has the right to withdraw such consent at any time. Withdrawal of the consent of the data subject is not applicable in the cases when the processing of the data is based on the provisions of items "a" and "b" above.


6. BBlinkio OÜ, in its capacity as controller/processor, does not process personal data which reveal racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, and the processing of genetic data, biometric data solely for the purpose of identification of the natural person, data concerning health or data concerning sex life or sex orientation of the natural person unless the data subject has given an explicit consent for the processing of such data for one or more specific purposes.


III.    Purpose of personal data processing 


7.Type of purpose

 

BBlinkio OÜ services are subject to laws and regulations requiring us to collect and use your personal identification information, formal identification information, financial information, transaction information, employment information, online identifiers, and/or usage data in certain ways.


BBlinkio OÜ must identify and verify customers in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. We process your personal information in order to provide our services to you.


Based on your direct marketing preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers based on your communication preferences. You can opt-out of our marketing communications at any time.


We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission.


BBlinkio OÜ may process the following data types:


  • Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, email, tax ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information;


  • Bank account information, payment card primary account number, transaction history, information about the transactions you make on our services, such as the name of the recipient, your name, the amount


  • Geo location/tracking details, browser fingerprint, OS, browser name and version, personal IP addresses;

  

Rights of the data subjects (customers – natural persons whom the data relates to)


8. Right to information (in relation to the processing of the data subject's personal data by BBlinkio OÜ - the natural persons that are data subjects have the right to receive information* as to the BBlinkio OÜ as personal data controller/processor, as well as the processing of their personal data


9. Right of access to own personal data - the data subjects have the right to receive from BBlinkio OÜ confirmation as to whether personal data related to them are processed and if so, to be given access to the data and the following information: purpose of the processing; respective personal data categories; personal data recipients or categories of recipients, if any; the intention of the controller to transmit personal data to a third party (where applicable); personal data storage period; existence of the right to correct personal data, as well as the right to object against the processing of personal data; existence of automated decision making, including profiling (if any); information as to all rights that the data subject has; the right to file a complaint with the supervision authority.


10. Right to rectification of personal data (if data is not accurate) - the data subject has the right to request BBlinkio OÜ to rectify, without undue delay, any incorrect data pertaining to the data subject.


11. Right to erasure of personal data (right "to be forgotten") - the data subject may request from BBlinkio OÜ to erase personal data, if any of the conditions listed below exist:


  • Personal data are no longer needed for the purposes they have been collected for or processed otherwise;


  • The data subject withdraws his / her consent, which data processing is solely based on, and no other legal grounds for the processing exist (processing due to regulatory obligation of BBlinkio OÜ, an agreement signed with BBlinkio OÜ);


  • The data subject objects against the processing and no legal grounds for the processing exist that prevail;

The personal data were processed unlawfully;


  • The personal data should be erased in order to comply with a legal obligation under the European Union law or the other applicable law which applies to BBlinkio OÜ in its capacity as personal data controller;


  • The personal data have been collected in relation to the offering of information society services to children and consent was given by the holder of parental responsibilities for the child.


12. Right to limitation of processing by BBlinkio OÜ or by the personal data processor - specific conditions are required to be in place for that right to be exercised, namely:


  • Accuracy / up to date nature of the data is disputed by the data subject. In this case the limitation of the processing is over a period allowing BBlinkio OÜ to check the accuracy of the personal data;


  • The processing is unlawful, but the data subjects do not wish their personal data to be erased, but rather require limitation of their use;


  • BBlinkio OÜ no longer needs such personal data for processing purposes, but the data subject requires them for establishing, exercising or defending legal claims;


  • The data subject has objected to the processing while awaiting a check to be performed on whether BBlinkio OÜ 's legal grounds prevail over the interests of the data subject.


13. Right to transferability (data portability) of the personal data between the various controllers - the data subjects have the right to receive personal data pertaining to them, which they have provided to BBlinkio OÜ in a structured, widely used and machine readable format and have the right to transfer such data to another controller without hindrance by BBlinkio OÜ to which personal data has been provided, when processing is based on consent or contractual obligation and the processing is automated. When exercising the right to transferability the data subject has also the right to receive direct transfer of the personal data from BBlinkio OÜ to another controller, where technically feasible.


14. Right to object against the processing of their personal data - data subjects have the right to object before BBlinkio OÜ against the processing of their personal data, whereby BBlinkio OÜ shall cease such processing, unless BBlinkio OÜ is able to prove that compelling legitimate grounds for the processing exist that override the interests, rights and freedoms of the data subject, or for the establishment, exercising or defence of legal claims. In case of objection against the processing of personal data for direct marketing purposes BBlinkio OÜ shall cease such processing forthwith.


15. The data subject also has the right not to be subject to decision based solely on automated processing, including profiling, which ensues legal consequences for the data subject or significantly affects the data subject otherwise.


16. Right to defence through judicial or administrative procedure if the data subject's rights have been breached - if the data subjects decide that their right to personal data protection and privacy has been violated, they may file a complaint with the relevant supervision authority -  or to file a claim with the court to defend their rights.

 

IV.    Disclosure of personal data


17. BBlinkio OÜ may disclose the personal data to the following categories of persons:


  • The persons whom the data relate to, namely: persons using BBlinkio OÜ services or products, or persons filing a request to use BBlinkio OÜ services, as well as persons who are party to BBlinkio OÜ and / or other transactions and contractual relations with BBlinkio OÜ;


  • Persons that have the right to access their personal data by virtue of law or another regulation;


  • Persons as to whom the right to disclosure is stipulated in an agreement signed with BBlinkio OÜ.


V.    Exercise the rights


18. (1) In exercising their right to access data, natural persons have the right to request from BBlinkio OÜ at any time:


1. Confirmation as to whether data related to them are processed by BBlinkio OÜ, the purpose of the processing, the data category and recipients of such data or the categories of recipients data are disclosed to;


2. To send them a message in an understandable format, containing the personal data subject to processing and any information available as to the source of such data;


3. Information as to the logic of any automated processing of personal data pertaining to natural persons, at least in the case of automated decisions under the provisions of the General Data Protection Regulation


(2) Upon request BBlinkio OÜ provides the information under paragraph 1 free of charge.


(3) Natural persons have the right to request at any time that BBlinkio OÜ:


1. erases, rectifies or blocks their personal data, the processing of which is not compliant with the requirements of the effective legislation


2. notifies the third parties to which the personal data of the natural persons have been disclosed as to any erasure, rectification or blocking in accordance with item 1 above, except when this proves to be impossible or would involve a disproportionate effort.


19. (1) Natural persons exercise their rights by filing a written request to BBlinkio OÜ, containing as a minimum the following information:


  1. name, personal ID number, address and other data allowing identification of the respective natural person;
  2. description of the request;
  3. Signature, date, correspondence address and telephone number.


(2) The filing of the request is free of charge.


(3) Upon filing of a request by an authorised person, the notarised power of attorney must be attached to the request.


(4) In case of death of the natural person, his / her rights are exercised by his / her heirs and certificate of heirs shall be attached to the request.


20. BBlinkio OÜ shall review and pronounce on the request within 1 month as of its filing. This period may be extended by a further two months, if necessary. BBlinkio OÜ informs the data subject as to any such extension within 1 month as of receipt of the request, stating the reasons for the delay. When the data subject files a request by electronic means, the information is provided electronically, if possible, unless the data subject has requested otherwise.


21. BBlinkio OÜ provides an answer to the requesting person taking into account their preferred form for the provision of the information (orally or in writing - as a hard copy of electronically).


22. Where data do not exist or their provision is forbidden by law, access of the requesting party to such data is refused.


23. If the requesting party is not satisfied with the response received and / or believes that their rights related to personal data protection were violated, they are entitled to exercise their right to defence.


VI.    Information for the data subject:



Contact details with BBlinkio OÜ


Name: BBLINKIO OÜ

ID number: 14718623

Address: Harju maakond, Tallinn, Kesklinna linnaosa, Pärnu mnt 41a-304, 10119

Manager: Iseki Solari

E-mail: [email protected]   

Telephone: +372 5331 2517

Internet site: https://www.bitcoinblink.com



Contact details with Data Protection Officer (Response person for GDPR):


Name: Dimitar Kolchakov

E-mail: [email protected]