§ 1 Glossary of Terms
1. Administrator: The personal data administrator according to GDPR, which is Emblematic.
2. Data Processor: Sum & Substance (UK) Ltd.
3. SumSub: Sum & Substance (UK) Ltd., located at 30 St. Mary Ax, London, England, EC3A 8BF. Data Protection Registration Number: ZA222205. Company Registration Number: 09688671.
4. Emblematic:
5. Personal Data: Users' personal data within the meaning of GDPR transferred in connection with the use of the Service.
6. Personal Data Processing: All operations performed on personal data within the meaning of GDPR.
7. GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (Journal of Laws EU 2016, item L119).
8. Services: All services provided by Emblematic, enabling Users to buy and sell virtual currencies.
9. Website: The internet website accessible via the egera.com domain and its subdomains.
10. User: Natural or legal persons who have accepted the Website Regulations and entered into an agreement with Emblematic for the provision of the Service.
§ 2 General Provisions
2. The Website collects information about Users and their behaviors through:
1. Data entered into forms by Users.
2. Data saved on end devices using cookies ('cookies').
3. Collection of web server logs and other information that arises (including automatically) in connection with or as a result of the operation and use of the Service.
4. Saving and collecting personal data in the form of recordings of the User's image obtained via a video communicator (e.g., Skype), in accordance with the provisions of the Website Regulations and the AML Policy.
§ 3 Principles of Data Collection
1. Data Requirement: To use the Services, Users must provide Personal Data. Failure to do so may prevent Emblematic from providing the Services.
2. User-Provided Data: The Website collects information provided by the User.
3. Data Sharing: Data obtained from Users will not be shared with third parties unless:
1. The User consents;
2. Required by law, including at the request of authorized bodies;
3. Necessary for providing the Services, particularly in technical aspects, payment processing, or other entities cooperating with Emblematic in providing the Service.
4. Data Processing Duration: Personal Data is processed for the duration of the Service Agreement.
§ 4 Scope of Personal Data and Their Processing
5. Data Requests: The Administrator may request the User to provide Personal Data, particularly in cases of:
1. Natural Person: Identification document designation, name, surname, citizenship, residence address, country of birth, tax residency information, political exposure status, telephone number, date of birth, and PESEL number. For foreign Users without a PESEL number, an equivalent national identification number or a declaration of not having such a number may be required.
2. Institutional User: Copy or scan of an excerpt from the relevant commercial register (e.g., National Court Register in Poland), and the data mentioned in section 1(a) for the person authorized to represent the Institutional User, as well as all actual beneficiaries of the User.
6. Data Verification: To verify data, the User may be required to present documents confirming identity and address validity, which can be done via distance communication channels (e.g., email, video messengers like Skype) as specified in the AML Policy.
7. GDPR Compliance: Personal Data is processed in accordance with GDPR.
8. Data Processing Basis: The basis for data processing is the User's consent and legal provisions authorizing personal data processing.
9. Data Sharing Restrictions: Personal Data will not be shared with other entities without the User's knowledge, except for entities authorized by law.
10. User Rights: The User has the right to inspect, modify, and delete their personal data, as long as it does not violate the law. This can be done via the User panel.
11. Administrator’s Refusal: The Administrator may refuse to exercise the rights specified in points 5 and 6 if:
12. Required by legal provisions,
13. The information is part of ongoing proceedings,
14. Necessary to explain circumstances of the User's violation of the Regulations.
§ 5 User Rights
15. Access and Correction: The User has the right to access and correct their Personal Data.
16. Data Modification Requests: The User can request:
17. Additions,
• Updates,
• Rectification of personal data,
• Temporary or permanent suspension of processing or deletion if data is incomplete, outdated, untrue, collected in violation of the law, or no longer necessary for the purpose it was collected.
18. Data Update Obligation: The User must update Personal Data via the User panel if changes occur.
19. Inquiries and Complaints: The User may seek explanations from the Administrator and has the right to submit inquiries, objections, or complaints to the supervisory authority if the Privacy Policy provisions are unclear.
20. No Automated Decisions: No automated decisions will be made based on the processed Personal Data. The data will not be used for profiling.
§ 6 Detailed Information About Cookies
1. Use of Cookies: The Website uses cookies.
2. Definition of Cookies: Cookies are IT data, specifically text files, stored on the User's end device to enable Website use. Cookies typically contain the name of their originating website, their storage duration on the end device, and a unique identifier.
3. Purpose of Cookies: Cookies are used to:
1. Create statistics to understand how Users utilize the Website, enabling improvements in structure and content.
2. Maintain the User's session (after logging in), so the User does not need to re-enter login credentials on each Website subpage.
3. Define the User's profile to display tailored materials in advertising networks, particularly the Google network.
4. Cookie Management: Emblematic places cookies on the User's end device and accesses them.
5. Cookie Restrictions: Limiting the use of cookies may affect some functionalities available on the Website.
6. Third-Party Cookies: Cookies placed on the User's end device may also be used by:
1. Entities cooperating with Emblematic.
2. Advertising networks, especially the Google network, to display ads tailored to the User's Website usage.
7. Managing Cookies: Users can view and edit cookie information using the tool at Google Ads Preferences and adjust browser settings accordingly.
§ 7 Server Layer – User Information
8. User Activity Logging: User activities are logged in the server layer. This data is used to administer the Website and may also be used as evidence in case of committed crimes or for pursuing civil claims.
9. Logged Information: Resources identified by URL addresses may include:
1. Time of inquiry arrival and response sending.
2. Information on errors occurring during HTTP and HTTPS transactions.
3. URL address of the previously visited page (referrer link).
4. Information about the User's browser.
5. IP address information.
10. User Association: The above data may be associated with specific Users.
§ 8 Entity Processing Personal Data
11. IT System Supplier: The Administrator declares that the IT system supplier, which stores the data referred to in § 7 and the history of operations performed by the User, is Sum & Substance (UK) Ltd.
12. Data Processor Role: Sum & Substance (UK) Ltd. acts as a Data Processor and has received consent from the Data Administrator to access service-related information as necessary for the IT system contract performance.
13. Processor's Commitment: The Processor has agreed to process the personal data entrusted to it in accordance with this Privacy Policy and other applicable laws protecting data subjects' rights.
14. Security Measures: The Processor has declared the application of technical and organizational security measures to ensure the security of processed personal data and to respect the rights of data subjects.
§ 9 Final Provisions
15. Contact Information: Users may contact the Administrator at any time for information via the following email address: support@emblematic.fi.