Date of Last Update: March 16, 2019 (“Revised Date”)
I. About this Policy
Protecting our customers' privacy is an important priority at Blueshare.io and we are committed to maintaining strong and meaningful privacy protections. The privacy of your information is a significant responsibility and we value the trust you place in us.
II. Who we are and how to contact us
The data controller for Blueshare.io is Interprom Mining AG, seated and managed at the following address: 6300 Zug, Gubelstrasse 11, c/o Sielva Management AG, together with its subsidiary Interprom EOOD a limited liability company based in Sofia, Bulgaria, registered under UIC 121115366 in the Commercial Register of Bulgaria (hereinafter “Blueshare.io”). Any Data subject may, at any time, contact any of us directly with all questions and suggestions concerning data protection.
Address: Interprom Mining AG, 6300 Zug, Gubelstrasse 11
Telephone: +41 76 320 89 83
Data Protection Officer
Blueshare.io has also designated a data protection officer (DPO) who oversees the processing of personal data in our company.
Our DPO is Vasil Vajarov. You can contact him by using one of these contact details:
Telephone: +359 88 723 34 41
III. Managing Your Information Preferences
1. Personal data is any information relating to an identified or identifiable natural person;
2. Data subject is any identified or identifiable natural person;
3. Processing is any operation or set of operations which is performed on Personal data or on sets of Personal data;
4. Рseudonymisation means the processing of personal data in such a manner that the Personal data can no longer be attributed to a specific Data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the Personal data are not attributed to an identified or identifiable natural person;
5. Controller is the legal person Blueshare.io which alone determines the purposes and means of the processing of Personal data;
6. Processor is a natural or legal person, public authority, agency or other body which processes Personal data on behalf of a controller;
V. What personal data we collect and how we use it
While browsing or using some of the functionalities on our website as well as by using cookies, Blueshare.io collects personal data.
Amongst other, the personal data that we collect includes:
- Your name;
- Your email;
- IP address;
- Device identification;
- Service and site usage information;
- Your display preferences, such as contrast color settings or font size.
Information we may collect automatically through cookies and other technologies
We may collect information about the products you looked at or searched for and the Site functions you used, including time spent and other statistical information. Details about your computers, devices, networks, including internet protocol (IP) address, cookie identifiers, MAC address, IMEI, Advertiser IDs, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, pages that you visit before and after using the services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Site, and other actions taken through use of the Site such as preferences.
The Blueshare site and Interprom Mining AG also collect IP addresses. An IP address is an unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our websites, blueshare.io may view and/or store the IP address of the device you use to connect to the Internet. Interprom Mining AG uses this information to determine the general physical location of the device and understand from what regions of the world our website visitors come from. Interprom Mining AG also may use this information to enhance Blueshare websites. We may collect information about the location of your device each time you use our platform based. Your location data will be obtained via a cookie. We use these cookies to identify and prevent potential security risks and to store preferences set by our users such as account name, language, and location. The information transmitted by the cookie is anonymous and is used by the Company in order to offer the relevant products in the specific territory or for advertising purposes.
Why do we collect your data?
If you express your explicit consent, your data will be used to provide information about promotions and other information related to our services. We use the information to respond to your inquiries. We will use the information to provide the services you have requested. We may use your information to improve our Site and services. The information we collect is to analyze the Site’s performance. Moreover we process your information on an anonymous basis to improve its performance and put suitable offers to you. We also use the information for marketing purposes for which you have the opportunity to opt out through our online form. We may also use your information to provide you with advertisements for our offers. In case you sign up for our newsletter, you will receive our promotional emails. We can also use your information to communicate with you. We can also use information in other ways which are permitted under current legislation.
Your personal data will also be processed in the cases when it is required by official public authorities or for the purposes of legal proceedings for consumer disputes, fraudulent activities etc.
- Blueshare.io also offers the possibility for purchase of blueshare tokens through the website which entails the provision of additional information.
Some of that information includes: data concerning the registration of the client (account name, password, etc.); data regarding the customer’s wallet; information regarding the planned investment;
The procedure for purchasing blueshare tokens requires setting up an additional user account on altcoinomy.com, Fully Verified, and ID Mind, and/or other KYC and AML providers.
Blueshare.io takes all necessary measures to ensure the confidentiality of the personal data. For more information on the methods we use, please turn to Chapter XIII: Security.
Along with these measures we also offer the possibility for every client to update his/her personal data. This can be done by using the functionalities of the Website.
For more information on the online platform or if for any additional questions, please don’t hesitate to contact us using one of the following ways:
- Email: firstname.lastname@example.org
- Telephone: +41 76 320 89 83
VI. What are the legal grounds for the processing
We collect your personal data only on the grounds allowed by the European legislation (specifically Regulation 2016/679 also known as General Data Protection Regulation). We collect your personal data on the following grounds:
- For the performance of a contract:
If you use our contact form or register as a user on our Site we may process personal data to perform our contractual obligation.
For the purposes of performing a contract we may also transfer the necessary personal data to third parties.
- For closely-related purposes:
Such as payment processing and financial account management, contract management, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance.
- Legitimate interest:
We store the information contained in your account on the grounds of the legitimate interest that both Blueshare.io and their customers have. We process this information to provide you with all the services that our online platform offers as well as to inform you about future projects or answer your queries.
We also store your data for the purposes of civil legal proceedings as well as administrative and criminal investigations to comply with the laws that are applicable to us around the world.
If you have presented to us any additional personal data (by including it in your written request, by presenting it through documents that you have applied in your request or by any other means), that personal data will be processed on the grounds of your consent.
You can withdraw your consent at any time by writing a short email to: email@example.com
VII. How do we protect your personal information
In order to provide your data, we have put in place technical and organizational measures that meet the GDPR requirements and require third-party service providers that we use to do the same. We take reasonable technical and organizational measures to prevent the loss, misuse or erasure of your personal information. We store all personal information you provide on our password-protected servers. All electronic financial transactions concluded through our Site are protected by encryption technology. Your data is stored only on secure servers accessible only by several authorized employees. When you use a form on our Site to send us data, this transmission is only through an encrypted TLS connection. Your information is stored and encrypted using the SSL/TLS certificate on the site.
VIII. How long we keep your personal data
In Blueshare.io we adhere to the principle of storage limitation. We store your personal data in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. We may keep personal data for longer periods of time insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.
Keeping your personal data is compliant with European legislation and in particular GDPR.
- Information in your client account: We process the information in your client account for as long as you are using our services.
- Correspondence and written requests: When you contact us for a certain reason we will keep your personal data for as long as it is necessary to answer your questions. After answering your question your personal data will be deleted within a month.
- Information gathered by cookies: The data collected by the Sites and/or through Cookies that may be placed on your computer will not be kept for longer than is necessary to fulfill the purposes for which it was collected. In any event, such information will be kept for a maximum of three (3) years.
Criteria for determining the storage periods:
- What is the purpose for using your personal data? (e.g. whether it is necessary for performing a contract)
- Do we have a legal obligation to store your personal data?
- Do we have any grounds to continue processing your information? (e.g. your consent)
- How valuable is your personal data?
- Any accepted practices for period of storage;
- The levels of risk of continuing to store your personal data;
- Any other circumstances (e.g. the current state of our contractual relationship).
IX. Do we transfer personal data to third parties, third countries and international organizations
Please, have in mind that the data transferred is limited to the purpose for which it is transferred. Blueshare.io takes into account that your personal data is a valuable asset. By adhering to that notion, we give access to information to third parties only after detailed documentation review and whether they meet the requirements of the applicable regulatory regime. This review carefully addresses the competence of each third party as well as technical and organizational data protection measures. We conclude agreements with any third party that we transfer information to, in order to ensure that your personal data is processed in a way that is compliant with GDPR.
We may disclose your personal information to the extent that we are obliged to do so by the legislation.
These are some of the third parties to which we transfer personal data:
- Private institutions (e.g. banks – if you have provided us with information about your bank account etc.);
- Official institutions (e.g. different government agencies);
- When necessary for legal proceedings (e.g. law offices – in order to prepare documents necessary for legal proceedings);
X. What are your rights and how to exercise them
The European legislation (GDPR) grants the data subjects a number of individual rights that can be exercised.
Here is a list of the rights you have under Regulation 2016/679:
1. Right of confirmation
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor confirmation as to whether or not Personal data concerning him or her are being processed.
If a Data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact the Controller/Processor.
2. Right of access
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor free information about his or her Personal data stored at any time and a copy of this information. Where the Data subject makes the request by electronic means, and unless otherwise requested by the Data subject, this information shall be provided in a commonly used electronic form. Furthermore, the European regulations grant the Data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- the envisaged period for which the Personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the Controller/Processor rectification or erasure of Personal data, or restriction of processing of Personal data concerning the Data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the Personal data are not collected from the Data subject, any available information as to their source;
- the existence of automated decision-making, including profiling.
Furthermore, the Data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the Data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a Data subject wishes to avail himself of this right of access, he or she may, at any time, contact the Controller/Processor.
3. Right to rectification
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor without undue delay the rectification of inaccurate Personal data concerning him or her. Taking into account the purposes of the processing, the Data subject shall have the right to have incomplete Personal data completed, including by means of providing a supplementary statement.
If a Data subject wishes to exercise this right to rectification, he or she may, at any time, contact the Controller/Processor or directly make the necessary changes from the functionalities of the account.
4. Right to erasure (Right to be forgotten)
Each Data subject shall have the right granted by the European legislator to terminate his or her account and obtain from the Controller/Processor the erasure of Personal data concerning him or her without undue delay and, and the Controller/Processor shall have the obligation to terminate the account and erase the Personal data without undue delay, as long as the there is no other legal ground for the processing.
If a Data subject wishes to terminate his or her account and erase his or her Personal data stored by us, he or she may, at any time, contact the Controller/Processor or directly erase his/her account.
5. Right of restriction of processing
Each Data subject shall have the right granted by the European legislator to obtain from the Controller/Processor restriction of processing where one of the following applies:
- accuracy of the Personal data is contested by the Data subject, for a period enabling the Controller/Processor to verify the accuracy of the Personal data;
- processing is unlawful and the Data subject opposes the erasure of the Personal data and requests instead the restriction of their use instead;
- Controller/Processor no longer needs the Personal data for the purposes of the processing, but they are required by the Data subject for the establishment, exercise or defense of legal claims;
- Data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the Controller/Processor override those of the Data subject.
If one of the aforementioned conditions is met, and a Data subject wishes to request the restriction of the processing of Personal data, he or she may at any time contact the Controller/Processor.
The Controller/Processor, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the Personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Controller/Processor shall inform the Data subject about those recipients if the Data subject requests it. We will arrange all the necessary measures in any individual cases.
6. Right to data portability
Each Data subject shall have the right granted by the European legislator, to receive the Personal data concerning him or her, which was provided to a Controller/Processor, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the Controller/Processor to which the Personal data have been provided, as long as the processing is based on consent, or on a contract, and the processing is carried out by automated means.
Furthermore, in exercising his or her right to data portability, the Data subject shall have the right to have Personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the Data subject may at any time contact the Controller/Processor.
7. Right to object
Each Data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of Personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
The Controller/Processor shall no longer process the Personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data subject, or for the establishment, exercise or defense of legal claims.
If the Controller/Processor processes personal data for direct marketing purposes, the Data subject shall have the right to object at any time to processing of Personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the Data subject objects to the processing for direct marketing purposes, we will no longer process the Personal data for these purposes.
In addition, the Data subject has the right, on grounds relating to his or her particular situation, to object to processing of Personal data concerning him or her by the Controller/Processor for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the Data subject may contact the Controller/Processor. In addition, the Data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
8. Automated individual decision-making, including profiling
We use profiling and analytics to understand how individuals use our products, for product development purposes and business intelligence purposes. These analytics help us understand and improve our products and better serve our clients and consumers. We also use analytics for security and anti-fraud purposes, such as to identify unauthorized use of payment cards.
We will not make automated-decisions about you that may significantly affect you, unless (1) the decision is necessary as part of a contract that we have with you, (2) we have your explicit consent, or (3) we are required by law to use the technology.
9. Right to withdraw data protection consent
Each Data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her Personal data at any time.
If the Data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact the Controller/Processor.
10. Right to a complain
Each Data subject shall have the right granted by the European legislator to lodge a complaint with the competent supervisory authority and before the competent courts of the Member States of his or her habitual residence, place of work or place of the alleged infringement if the Data subject considers that the processing of personal data relating to him or her is in breach of the provisions of the GDPR.
The competent supervisory authority in Switzerland is the Federal Data Protection and Information Commissioner ('FDPIC') with address Feldeggweg 1 CH - 3003 Berne Switzerland, Phone: +41 (0)58 462 43 95.
11. Right to information on action taken
Each Data subject shall have the right granted by the European legislator to be provided by the Controller/Processor with information on action taken on a request without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. The Controller/Processor shall inform the Data subject of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the Data subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the Data subject.
12. Right to information in case of data breach
Each Data subject shall have the right granted by the European legislator to be informed without undue delay by the Controller/Processor about a personal data breach which is likely to result in a high risk to the rights and freedoms of natural persons.
XI. ADDITIONAL REMARKS AND GUARANTEES
We will not disclose any personal information that has been requested to the extent permitted by law.
We do not intend to collect information about children under the age of 18 who can be identified without the permission of their parent or guardian. We do not knowingly collect information, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of majority, we will promptly delete it.
XII. HOW TO EXERCISE YOUR RIGHTS
- In person:
- City: Zug
- Address: 6300, Gubelstrasse 11
- By a phone call:
- Telephone number: +41 76 320 89 83
- Website: https://www.blueshare.io
- Email: firstname.lastname@example.org
- Contact details of the Federal Data Protection and Information Commissioner ('FDPIC'):
- Address: Feldeggweg 1 CH - 3003 Berne Switzerland
- Call center - tel. +41 (0)58 462 43 95
- Е-mail: email@example.com
- Web-site: https://www.edoeb.admin.ch
We have implemented all kinds of technical and organizational measures to ensure that processing is carried out in accordance with the GDPR, including:
1. pseudonymisation of Personal data;
2. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
3. the ability to restore the availability and access to Personal data in a timely manner in the event of a physical or technical incident;
4. a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.
These measures are designed to implement data protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of data subjects.