Blockrise Capital B.V. (hereinafter also Blockrise, we us, our) is a private company with limited liability, situated in the Netherlands.
Which personal information do we collect?
Personal Information we collect
We may collect the following categories of Personal Information from you (which includes you as a (potential) Blockrise account holder, and for legal entities this also includes ultimate beneficial owners, representatives and directors):
- identification information, such as name, email address, phone number, postal address, driver’s license number and/or passport number;
- commercial information, such as trading activity, order activity, deposits, withdrawals, account balances;
- financial information, such as bank account and wallet information and source of wealth information;
- correspondence, including information provided during account opening and customer support;
- sensory information, such as images collected for identity verification, audio recordings;
- employment information, such as job title, name of employer, salary; and
- company information, such as the company’s legal name, proof of legal existence (which may include articles of incorporation, certificate of incorporation, business license or other comparable legal document, financial information, information about the structure of the company and about its group companies, information about its activities, information about the ultimate beneficial owners and directors and/or authorised representatives).
Personal Information we collect automatically
We may collect the following categories of Personal Information automatically through your use of our services:
- online identifiers, such as IP address; domain name;
- device information, such as hardware, operating system, browser;
- usage data, such as system activity, internal and external information related to Blockrise pages that you visit, clickstream information; and
- geolocation data.
Personal Information we may collect from third parties
We may collect and/or verify the following categories of Personal Information relating to you from third parties:
- identification information, such as name, email, phone number, address, driver’s license number or passport number;
- financial information, such as bank account and wallet information and source of wealth, information;
- transaction information, such as public blockchain data (bitcoin, ether and other digital assets are not anonymous). We can match your public digital asset address to other Personal Information about you and may be able to identify you from a blockchain transaction because – in some circumstances – Personal Information published on a blockchain (such as your digital asset address and IP address) can be correlated with Personal Information that we may have. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Information about you; and
- additional information, as requested by and at the discretion of our compliance team (which may include criminal records or alleged criminal activity).
Personal Information you provide during the registration process may be retained, even if your (request for) registration is left incomplete or not finalised or not approved by us.
Accuracy and retention of Personal Information
We take reasonable and practicable steps to ensure that your Personal Information is not kept longer than is necessary for the fulfilment of the purpose for which it is used and no longer than required on the basis of applicable rules and regulations.
How can we use Your Personal Information?
The Personal Information we collect and the practices described above are for the purpose of providing you with the best service possible, protecting you from risks related to improper use and fraud, and helping us maintain and improve Blockrise and helping us to comply with applicable rules and regulations. We may use your Personal Information to:
- Provide you with our services. We use your Personal Information to provide you with our services pursuant to the terms of your agreement with us. For example, in order to facilitate fiat transfers to or from your account, we need to know your bank account information.
- Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations. For example, we have identity verification requirements to fulfil our obligations under anti-money laundering laws and sanction rules.
- Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
- Protect the security and integrity of our services. We use your Personal Information to further our security-first mentality. Maintaining the security of your account and the exchange requires us to process your Personal Information, including information about your device and your activity on the exchange, and other relevant information.
- Provide you with customer support. We process your Personal Information if you reach out to our customer support team.
- Optimise and enhance our services. We use your Personal Information to understand how our products and services are being used to help us improve our services and develop new products.
- Market our products to you. We may contact you with Personal Information about our products and services. We will only do so with your permission, which can be revoked at any time.
- Other business purposes. We may use your Personal Information for additional purposes if that purpose is disclosed to you before we collect such Personal Information or if we obtain your consent.
What is the basis for data processing?
Under the GDPR, processing must be based on one of the lawful bases. The basis for processing will be one of the following, depending on the specific personal data: a legal obligation, a contract, a legitimate interest, or consent.
How/when can We share Your Personal Information?
We will not share your Personal Information with third parties, except as described below:
- Service providers and cooperation and outsourcing partners.
We may share your Personal Information with third-party service providers for business or commercial purposes, including our outsourcing and cooperation partners. Your Personal Information may be shared so that they can provide us with services, including identity verification, fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, information technology, advertising, marketing, data processing, network infrastructure, storage, transaction monitoring, and tax reporting. We share your Personal Information with these service providers only so that they can provide us with services and so that they can comply with rules and regulations that apply to us and/or to them, and we prohibit our service, cooperation and outsourcing partners from using or disclosing your Personal Information for any other purpose. The third-parties are subject to strict confidentiality obligations under a data processing agreement.
- Rules and regulations and law enforcement.
We may be required to share your Personal Information on the basis of applicable rules and regulations, a court order or an information request from an authorised supervisory authority. We may be required to share your Personal Information with law enforcement, government officials and/or regulators, including financial intelligence units.
- Corporate Matters.
We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganisation, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
- Professional advisors.
We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits, business purposes or to comply with our legal obligations.
We may share or disclose your Personal Information with your consent.
What are Your rights with regard to personal data?
If we process your personal data, you have the following rights: the right to access, rectify and erase of your personal data and the right to restriction of processing of your personal data. In some cases, you also have the right to object to the processing of your personal data or the right to request the transfer of your data. Please note that under certain circumstances, there are limitations to these rights. To make a request relating to these rights, please contact us via the contact details below. In case of doubt about your identity, we may ask you to identity yourself.
If you are a European resident and you believe that we have not adequately resolved any such issues, you have the right to contact the local supervisory authority.
How long do we retain personal data?
We will not retain your personal data for any longer than necessary for the purposes for which we use them. By law, we are required to retain certain data for a specific period.
- help us recognise you as a client;
- store information on preferred language, time zone and other preferences.
- collect information about your computer or other access devices to ensure compliance with anti-money laundering rules and regulations;
- ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities.
We do not use (third party) marketing cookies. We do use Google Analytics in accordance with the Guidelines provided by the Dutch Data Protection Authority, which means inter alia that we have concluded a data processing agreement with Google, we have masked the last octet of IP-addresses, we have switched off data sharing and we do not use other Google services in combination with Google Analytics cookies.
Please note that if you reject cookies, you will not be able to use some or all parts of the Blockrise services.
Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from or relating to you. You may opt-out of such communications at any time by using the “unsubscribe” button. You may also opt-out of such communications by following the directions provided in any marketing communication. We do not provide your Personal Information for those third parties’ direct marketing purposes without your consent.
We cannot guarantee absolute security, but we work hard to protect Blockrise and you from unauthorized access to or unauthorized alteration, unlawful processing, disclosure, or destruction of the Personal Information we collect and store. Measures we take include:
- encryption of the Blockrise website communications with SSL;
- require two-factor authentication for all sessions;
- periodic review of our Personal Information collection, storage, and processing practices; and
- restricted access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or their engagement terminated if they fail to meet these obligations.
Contact Details Blockrise Capital B.V.