Privacy Policy

Introduction

At Coinslr, we are dedicated to safeguarding your privacy and personal data, in compliance with the applicable regulations in Poland, including the General Data Protection Regulation (GDPR) (EU) 2016/679, and other relevant legal requirements of the European Union and Poland. This Privacy Policy has been developed to provide you with clear information on how we process and protect your personal data and to explain your rights with respect to the privacy and security of your data.

Terms

  • Data Subject – A natural person whose personal data is being processed.

  • Data Controller – The entity responsible for determining the purposes and means of processing personal data. This entity is:
    Coinsellor sp. z o.o. , registered under NIP: 7011176752 , located at UL. STEFANA BATOREGO 18/108, 02-591, Poland; contact email: contact@coinsellor.com.

  • Personal Data – Any information that relates directly or indirectly to an identified or identifiable individual, including, but not limited to, name, surname, identification number, contact details, video surveillance data, economic activities, and other personal information.

  • Processing of Personal Data – Any operation or set of operations performed on personal data, such as collection, organization, storage, use, disclosure, transmission, or deletion.

  • Consent – A clear and voluntary agreement by the Data Subject to the processing of their personal data for specific purposes.

Principles of personal data processing

At Coinslr, we process personal data in accordance with the GDPR, adhering to the following principles:

  • Legality, Fairness, and Transparency – Personal data is processed lawfully, in a transparent manner, and with fairness to the Data Subject.

  • Purpose Limitation – Personal data is collected for specific, legitimate purposes and will not be processed in a way that is incompatible with those purposes.

  • Data Minimization – Personal data is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.

  • Accuracy – Personal data is accurate and, if necessary, kept up to date. We take all reasonable steps to ensure that inaccurate data is corrected or erased.

  • Storage Limitation – Personal data is stored only for as long as necessary for the purposes of processing.

  • Integrity and Confidentiality – Personal data is processed securely, ensuring protection against unauthorized access, loss, destruction, or damage.

What personal data is processed?

In accordance with the purposes outlined in this policy, we process the following categories of personal data:

  • Identification Data – such as name, surname, personal identification number, date of birth, and other identification details from your identification document (e.g., passport, ID card).

  • Contact Data – such as address, telephone number, and email address.

  • Tax Residence Information – including your country of tax residence, taxpayer number, citizenship, and place of tax residence.

  • Communication Data – information obtained from communications such as letters, emails, phone calls (with or without audio recording), and data related to the devices and technologies used for communication.

  • Investment and Cryptocurrency Data – including information related to your investment portfolio, cryptocurrency balances, transfers, and fees associated with virtual currency transactions.

  • Financial Knowledge – such as your education, financial knowledge, and investment experience.

  • Transaction Data – information related to the services you have used or requested, complaints, and contractual details.

  • Financial Data – including the source of funds, financial liabilities, assets, transactions, income, and expenditures.

  • Employment and Economic Activity Data – including employment details, business activity, income stability, and sources of profit.

  • Audio and Video Surveillance Data – visual and audio data collected from security surveillance when visiting our premises.

Legal basis for processing personal data

The processing of your personal data is lawful if based on at least one of the following grounds:

  • Performance of a contract – processing is necessary for entering into or performing a contract.

  • Legal Obligation – processing is necessary for compliance with a legal obligation to which we are subject.

  • Consent – processing is based on your consent for specific purposes.

  • Legitimate Interest – processing is necessary for the legitimate interests of [Company Name] or a third party, provided these interests are not overridden by your privacy rights.

Purposes for which personal data is processed

We process your personal data for the following main purposes:

  • Providing you with the services you have requested or contracted for.

  • Risk assessment, identification, and documentation of transactions.

  • Protection of your cryptocurrency assets.

  • Compliance with legal and regulatory requirements, including anti-money laundering obligations.

We may also process your data for the following secondary purposes:

  • To verify your identity.

  • To assess the suitability of our products and services based on your financial profile.

  • To conduct video surveillance for security purposes.

  • To improve our services and handle customer inquiries and complaints.

  • For marketing activities, when required by your consent.

  • For compliance with regulatory requirements and reporting obligations.

How personal data is collected

Your personal data is collected in the following ways:

  • Directly from you, such as when you apply for services, contact us, or use our website

  • Through third parties, such as partners, service providers, or regulatory authorities.

  • Through monitoring activities, including security cameras at our premises.

Camera surveillance

To ensure the safety of our employees, clients, and assets, we use video surveillance in our office premises. The areas under surveillance are clearly marked. The data collected includes video footage and audio recordings. This data is processed based on our legitimate interest in maintaining security and is retained for a maximum of 60 days.

Recipients of persona data

Your personal data may be shared with:

  • Service providers and third parties involved in the execution of transactions.

  • Regulatory authorities and law enforcement agencies as required by law.

  • Public institutions or other authorities when necessary.

  • Our partners or processors who help us provide services to you.

Automated desicion making and profiling

We may engage in automated decision-making, including profiling, for purposes such as marketing or assessing the suitability of our services for your needs. This allows us to send targeted offers or evaluate potential risks. You have the right to object to such automated decisions, particularly if they significantly affect your rights.

Transfer of personal data outside the EU/EEA

We do not transfer your personal data outside the European Union or the European Economic Area.

Data retention periods

Your personal data will be retained for no longer than necessary for the purposes of processing. Specific retention periods are determined based on:

  • The need to fulfill contractual obligations.

  • Compliance with legal requirements, such as anti-money laundering laws.

  • The protection of our interests in the case of potential claims.

Your rights regarding personal data

You have several rights with respect to your personal data, including:

  • Access – You can request confirmation of whether we process your personal data and access the data we hold about you.

  • Rectification – You can request that we correct any inaccurate or incomplete personal data.

  • Deletion – You can request that we delete your personal data when it is no longer necessary for the purposes of processing.

  • Restriction – You can request that we restrict the processing of your data in certain circumstances.

  • Portability – You can request that we transfer your personal data to another service provider in a structured, commonly used, and machine-readable format.

  • Objection – You can object to the processing of your data based on our legitimate interests, and we will stop processing it unless we have overriding legitimate grounds.

  • Automated Decision Making – You can object to decisions based solely on automated processing, including profiling, that significantly affect you.

Submission of a request

You can submit your request to exercise any of your rights by sending an email to contact@coinsellor.com. We will respond to your request as soon as possible, and no later than one month from receipt. If necessary, we may extend this period by up to two months, informing you of the reasons for the delay.

Security of personal data

We implement appropriate technical and organizational measures to safeguard your personal data and ensure that it is protected from unauthorized access, loss, or damage.

Amendments to this policy

We may update this Privacy Policy in response to legal changes or modifications to our services. You will be informed of any changes, and the updated policy will be available on our website.

This Privacy Policy reflects our commitment to protecting your personal data and ensuring your privacy rights are respected.

We fully understand the importance of choosing the right partner for this service.

We are always here to assist you, so feel free to reach out with any questions or concerns.

Get in touch