Virtual Financial Asset
As used herein, “Virtual Financial Asset” under Malta’s Virtual Financial Asset Act, 2018, also called “convertible virtual currency,” “cryptocurrency,” or “digital goods”, such as bitcoin or ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.
As used herein, “Personal Data” means any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.
2.WHAT PERSONAL DATA WE COLLECT
Bingbon collects, processes, and stores Personal Data collected from you via your use of the Service or where you have given your consent. This Personal Data may include contact details, copies of identification documentation provided by you or derived from publicly accessible databases, your government identification number as well as information relating to your device or internet service (such as an IP address and a MAC number).
We collect information you provide during the Bingbon onboarding process, which may be a completed, incomplete, or abandoned process. We collect, use, store, and transfer your Personal Data, which may include the following:
Operating within the European Economic Area (“EEA”), we collect, store, and process your personal information in accordance with the provisions of the General Data Protection Regulation (GDPR) and Data Protection Act. To understand more about how we protect the data collected from individuals and entities located within the EEA, please see the details below.
Mobile phone number
Full legal name (including former name, and names in local language)
Passport number, or any government issued ID number
Date of birth (“DOB”)
Proof of identity (e.g. passport, driver’s license, or government-issued ID)
Proof of residency
Additional Personal Data or documentation at the discretion of our Compliance Team
Corporate legal name (including the legal name in local language)
Full legal name of all beneficial owners, directors, and legal representatives
Address (principal place of business and/or other physical locations)
Proof of legal existence
Description of the business
Percentage of ownership for Individual/corporate owners
Contact information of owners, principals, and executive management (as applicable)
Proof of identity (e.g., passport, driver’s license, or government-issued ID) for significant individual beneficial owner of the institutional customer entity
Personal Data for each entity’s significant beneficial owner of the institutional customer entity (see the “Individual Customer” section above for details on what Personal Data we collect for individuals)
Source of wealth
Amount of bitcoin or other digital assets projected to be injected
3.COLLECTION AND TRANSFER OF DATA OUTSIDE OF THE EEA
As outlined above, we may collect Personal Data from customers located in the EEA. To facilitate the services we provide to customers located in the EEA, we request explicit consent for the transfer of Personal Data from the EEA to outside of the area. If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to use Bingbon and our services. You will have the ability to withdraw your digital assets; however, all other functionalities will be disabled.
4.HOW WE USE YOUR PERSONAL DATA
Bingbon uses Personal Data to communicate with you and to administer, deliver, improve, and personalize the Service. Bingbon might also generate generic data out of any Personal Data we collect and use it for our own purposes. We may also use such data to communicate with you in relation to other products or services offered by Bingbon and/or its partners. We do not share your Personal Data with third parties (other than partners in connection with their services to Bingbon) except where you have given your consent and further detailed below.
We may share your Personal Data with third parties:
(a) if we think that sharing it is necessary to enforce the Terms of Service；
(b) to comply with government agencies, including regulators, law enforcement and/or justice departments；
(c) to third parties who provide services to Bingbon (such as administration or technical services)；
(d) in connection with the sale or transfer of our business or any part thereof.
Additionally, we have implemented international standards to prevent money laundering, terrorist financing and circumventing trade and economic sanctions and will implement final Virtual Financial Asset rules and regulations when effective, which will likely require us to undertake due diligence on our customers. This may include the use of third-party data and service providers which we will cross-reference with your personal information.
5.HOW WE STORE YOUR PERSONAL DATA
We aim to protect users and Bingbon from unauthorized access, alteration, disclosure, or destruction of the personal data that we collect and store. We take various measures to ensure information security. We store your data securely in fault-tolerant secure storage which is encrypted with industry standards, and take multiple security measures to ensure that user data will not be lost, abused, or altered, including but not limited to:
5.1 Physical Measures
Materials containing your personal information will be stored in a locked place. Your personal information will only be stored in the physical form under special circumstances.
5.2 Electronic Measures
Computer data containing your personal information will be stored in the computer systems and storage media that are subject to strict login restrictions.
5.3 Management Measures
Only authorized employees are permitted to come into contact with your personal information and such employees must comply with our internal confidentiality rules for personal data. We have also imposed strict physical access controls to buildings and files. In addition, we continuously train staff on relevant laws and regulations and privacy security guidelines, and security awareness, and regularly organize emergency response training and emergency drills for relevant internal personnel to master their job responsibilities and emergency response strategies and protocols.
5.4 Technical Measures
We use various currently available general security technologies and supporting management systems to minimize the risks that your personal information maybe be disclosed, damaged, misused, accessed without authorization, disclosed without authorization, or altered. These technologies include but are not limited to, Secure Hash Algorithm (SHA) for data encryption storage, Secure Sockets Layer (SSL) authentication for data encrypted transfers, and Multi-factor Authentication (MFA) for data security verification, and other strict security measures such as access control, de-identification, desensitization, and full disk encryption.
5.5 Other Measures
Our web server is protected by various "firewalls".
Please note that it is impossible to guarantee 100% security of information. As such, we request that you understand the responsibility to independently take safety precautions to protect your own personal information.
Here are some safety steps that you need to know about.
5.6 Use a strong user identification, password, and PIN to access accounts that others do not know or cannot easily guess ("User Credentials"). The user credentials must meet the requirements we specified when you create them. You should keep your user credentials safely and privately and do not share your user credentials with anyone.
5.7 Anti-virus, anti-spyware and firewall software are recommended to be installed on personal computers and mobile devices.
5.8 The operating system, anti-virus and firewall products should be updated regularly and updated to the latest security patches or versions.
5.9 File and printer sharing in the computer should be deleted, especially when they are connected to the Internet.
5.10 Back up your critical data regularly.
5.11 Consider using encryption technology to protect highly sensitive or confidential information.
5.12 After completing each online session using the platform, log out completely and clear the browser cache.
5.13 Do not install software or run programs from unknown sources.
5.14 Delete spam emails or chain letters.
5.15 Do not open email attachments from strangers.
5.16 Do not disclose personal, financial, or credit card information to little-known or suspicious websites.
5.17 Do not use untrusted computers or equipment.
5.18 Do not use public or Internet cafe computers to access online services or conduct financial transactions.
If you suspect that your personal information, especially account and/or password information, has been compromised, please lock your account immediately and contact our customer support team.
6.ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL DATA
You have the right to obtain a copy of your Personal Data upon request and ascertain whether the information we hold about you is accurate and up-to-date. If any of your Personal Data is inaccurate, you may request to update your information. You may also request to delete your Personal Data, with exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. For data access, correction, or deletion requests, please contact support@Bingbon.com with the subject “DATA INQUIRY”.
In response to data access, correction, or deletion request, we will verify the requesting party’s identity to ensure that he or she is legally entitled to make such request. While we aim to respond to these requests free of charge, we reserve the right to charge you a reasonable fee should your request be repetitive or onerous.
Customers can opt out from these marketing communications at any moment. If you do not want to receive these communications, please send an email to support@Bingbon.com .
For product related communications, such as policy/terms updates and operational notifications, you will not be able to opt out of receiving such information.
While you access Bingbon, we may use the industry practice of placing a small amount of data that will be saved by your browser (Cookies). This information can be placed on your computer or other devices used to visit Bingbon. This information help us recognize you as a customer, collect information about your use of Bingbon to better customize our services and better your experience. We may also use the information collected to ensure compliance with our compliance program, and to ensure your account security has not been compromised by detecting irregular or suspicious account activities.
Most browsers are setup to accept cookies automatically. Some Cookies expire when you finalize the session and other Cookies remain on your computer or other devices until deleted or expired. You have the option to decline the use of our Cookies, but this may affect the functionality of Bingbon services or your user experience.
9.CONTACTING Bingbon ABOUT PRIVACY QUESTIONS OR CONCERNS