Privacy policy

Identification
- Holder: CRIPTAN TRADE S.L. (hereinafter, "CRIPTAN")
Registered Office: Calle Sueca 40 Bajo 3, 4619 (Gilet), Valencia (Spain)
NIF: B-98992738
Public Registry: Commercial Registry of Valencia, Volume 10523, Book 7804, Folio 110, Section 8, Sheet V-182811
Email: atencion@criptan.es

Information
Through this Privacy Policy, the user (hereinafter referred to as the "User") is unequivocally informed that the personal data provided via the Criptan website (hereinafter, the "Website"), as well as (ii) through the Criptan mobile application (hereinafter, the "Application") and (iii) similar environments such as forms or contact email, will be processed by CRIPTAN in accordance with the provisions set forth in this Privacy Policy.

The User should read this Privacy Policy carefully, which has been written in a clear and simple manner to facilitate its understanding.

Obligation to provide personal data
The data requested in the forms on the Website and the Application are generally mandatory (unless otherwise specified in the required field) to meet the purposes for which they are collected.

Therefore, if they are not provided or are not provided correctly, CRIPTAN will not be able to adequately provide its services.

Personal data collected on the website and the application
The personal data that may be collected by CRIPTAN on the Website and the Application include:

- Copy of ID or identification document.
- Facial photograph (not retained indefinitely).
- Email address.
- Telephone number.
- Full personal or tax postal address.
-First and last name.
- Bank account number.
- Photograph of bank card.

Purpose of processing user data by Criptan
The personal data provided through the Website and the Application will be processed by CRIPTAN according to the following purposes:

- Identification and Onboarding of Users for service provision: to identify the User so that they can access the services provided on the Website and the Application, as well as the data necessary to carry them out.

- Response to issues raised in contact forms and email: to manage, process, and respond to requests, inquiries, incidents, or consultations of the User.

- Attention to the exercise of Users' rights: to process, analyze, answer, and, if applicable, execute the exercise of rights requested by the User in accordance with the provisions of this Privacy Policy.

- Conducting quality and satisfaction surveys: conducting surveys with Users regarding the quality and their satisfaction with the services provided by CRIPTAN. Analysis of the reports and statistics obtained from the responses of the Users.

- Sending of commercial communications: sending commercial communications via telematic or conventional means about CRIPTAN.

Basis for legitimization of user data processing by Criptan
The legitimization for processing the User's personal data will be as follows:

- Identification and Onboarding of Users for service provision: data processing derived from this purpose is the fulfillment of the contractual relationship or for the application at the User's request of pre-contractual measures, and on certain occasions for the fulfillment of a legal obligation as provided by applicable regulations.

As subjects obligated by the regulations on money laundering, based on article 4 of Royal Decree 304/2014, of May 5, which approves the Regulation of Law 10/2010, of April 28, on the prevention of money laundering and terrorist financing; we must collect our users' facial data with the goal of verifying their identity, contrasting it with the data reflected in their ID.

- Response to issues raised in contact forms: the data processing derived from this purpose is the fulfillment of the contractual relationship or for the application at the User's request of pre-contractual measures.

- Attention to the exercise of Users' rights: all processing derived from this purpose will have as a basis of legitimization the fulfillment of legal obligations, as established in the applicable data protection regulations.

- Conducting quality and satisfaction surveys: the treatments derived from conducting quality and satisfaction surveys will have as a basis of legitimization the legitimate interest, recognized to the data controller by the regulations.

This legitimate interest is based on being able to offer Users the services of CRIPTAN, both on the Website and in the Application with the highest quality and best possible experience for the User.

- Sending of commercial communications: The treatment derived from this purpose will have as a basis of legitimization the consent, recognized to the data controller by the regulations.

The User has the right to object to the processing of their personal data for the purpose of sending personalized commercial communications, at any time and at no cost. The user can express such opposition by clicking on the link established to unsubscribe from commercial communications or by sending an email to the following email address: atencion@criptan.es.

Additionally, in the event that the User provides their consent for CRIPTAN to process their data for any additional purpose mentioned in this Privacy Policy, the User will be duly informed of such processing, with the User being empowered to revoke such consent by contacting CRIPTAN through the following email address: atencion@criptan.es.

Who will user data be shared with?
User data may be communicated to:

- Public Administrations in cases provided by law.

- Courts and Tribunals in cases provided by law.State Security Forces and Corps in cases provided by law.

- Companies that are part of the CRIPTAN group for internal administrative purposes.

- Companies with which CRIPTAN carries out commercial operations, provided that the treatments are necessary for the proper end of the operation and guarantee, where appropriate, the continuity in the provision of services offered to Users, this includes, in particular, facial data.

These facial data are shared with our provider, MetaMap, whose website you can consult here https://es.metamap.com. This provider does not share the information it collects with third parties, and stores this information on Amazon Web Services (AWS) servers located in Frankfurt (Germany). You can access the information on data privacy in MetaMap's privacy policy regarding facial data in sections A and C of their Privacy Policy.

International data transfers
CRIPTAN does not intend to transfer the personal data of Users to a third country or international organization. However, in the event that this were the case, Users would be expressly informed of this circumstance indicating the existence or absence of an adequacy decision by the European Commission, or, the appropriate safeguards and the means to obtain a copy of these.

Data retention periods
The data of the User will be retained for the following periods:

1. Identification and Onboarding of Users for service provision will be retained for the period necessary for the provision of services from the Website or Application at the request of the User and, once these services are concluded, for the period of prescription of legal actions derived from the aforementioned provision of services.

With respect to facial data, as it involves a verification required at the time of onboarding our Users, these will be deleted once the data verification process of the Users is completed when accessing for the first time.

2. Data provided through contact forms will be retained for the period necessary to process and respond to your request and, once concluded, for the period of prescription of legal actions derived from the aforementioned request.

3. Data used to attend to the exercise of rights of Users will be retained for the period necessary to carry out the right requested by the User and, once complied with such right, will be kept until the prescription of the potential responsibilities derived from this processing.

4. Conducting quality and satisfaction surveys will be retained for the time necessary to provide services to the Users and until they oppose or are no longer necessary to fulfill the established purpose and the potential responsibilities derived from the provision of services have expired.

5. Data used for sending commercial communications will be processed until the User objects or revokes their consent.

In any case, CRIPTAN will properly block the personal data of the Users, not having access to them at the time they are no longer necessary to fulfill the purpose for which they were collected, being only processed if required by the judicial or administrative authority competent in the cases expressly established by Law.

User responsibility
The user:

- Guarantees that they are over eighteen (18) years old and that the data they provide to CRIPTAN are true, accurate, complete, and up-to-date. For these purposes, the User is responsible for the veracity of all the data they communicate and will keep the information provided conveniently updated, so that it responds to their actual situation.

Guarantees that they have informed third parties whose data they provide, in case of doing so, of the aspects contained in this document. Likewise, guarantees that they have obtained their authorization to provide their data to CRIPTAN for the purposes indicated.

Will be responsible for false or inaccurate information they provide through the Website and the Application and for the direct or indirect damage this causes to CRIPTAN or third parties.

Exercise of rights
The User may send a letter to CRIPTAN, to the address indicated in the header of this Privacy Policy, or by means of an email to the address: atencion@criptan.com, attaching a photocopy of their identity document, at any time and free of charge, to:
- Revoke the consents granted.
- Obtain confirmation about whether CRIPTAN is processing personal data concerning the User or not.
- Access their personal data.
- Rectify inaccurate or incomplete data.Request the deletion of their data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
- Obtain from CRIPTAN the limitation of processing of the data when one of the conditions provided in the data protection regulations is met.
- Request the portability of the data provided by the User in those cases provided for in the regulations.

Additionally, they may file a complaint regarding the protection of their personal data with the Spanish Data Protection Agency at the address C/ Jorge Juan 6, 28001 - Madrid, when the interested party considers that CRIPTAN has violated the rights recognized by the applicable data protection regulations.

Security measures
CRIPTAN will process the User's data at all times in an absolutely confidential manner and keeping the mandatory duty of secrecy regarding them, in accordance with the provisions of the applicable regulations, adopting the necessary technical and organizational measures that guarantee the security of their data and prevent their alteration, loss, processing or unauthorized access, given the state of the technology, the nature of the stored data and the risks to which they are exposed.

Changes
CRIPTAN reserves the right to review its Privacy Policy whenever it deems appropriate, in which case it will be communicated to the Users. For this reason, we ask you to regularly check this privacy statement to read the most recent version of CRIPTAN's Privacy Policy.

Acceptance, consent and understanding
The User declares having been informed of the conditions on the protection of personal data, accepting and understanding the content of this Privacy Policy. Otherwise, please do not accept the Privacy Policy and/or do not use the Website and the Application.

Last updated: December 5, 2023.

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