Last modified: April 10, 2019
This Policy describes the types of information we may collect from you or that you may provide when you visit coincafe.com (our “Website”) and use our Services (“Coin Cafe Services”), and our practices for collecting, using, maintaining, protecting and disclosing that information.This Policy applies to information we collect:
- On this Website.
- In e-mail, text and other electronic messages between you and this Website.
- In telephone conversations or meetings with you to collect information required to use this Website.
- Us through any other means, including on any other website operated by the Company or any third party; or
- Any third party, including through any application or content (including advertising) that may link to, or be accessible from, or on the Website.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Website. Upon using Coin Cafe Services, you must affirmatively agree to this Policy prior to using the Services or registering a Coin Cafe Account (“Account”). This Policy may change from time to time. If material changes are made to this Policy, we will revise the date at the top of this page, and the changes will be prominently posted on the Website. Please check this Policy periodically for updates. Coin Cafe Account-holders will receive notification of changes made to this Policy.
Under the Age of 18
Coin Cafe’s Website and Coin Cafe Services are for adults only and all users must be at least 18 years old. If you are under 18 years old, do not: use or provide any information on this Website, or on, or through any of its features; register an Account on the Website; make any purchases through the Website; use any of the interactive or public comment features of this Website; or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received Personal Information from anyone under 18 years of age without verification of parental consent, we will delete that information. If you believe we might have any information from or about anyone under 18 years of age, please contact us at [email protected].
While users located within the European Economic Area (“EEA”) over the age of 16 may generally provide Personal Information without parental consent, Coin Cafe considers all users under 18 to be minors who require parental consent.
Personally identifiable information (“PII” or “Personal Information”) is any unique data or information that can be used to identify you. For California residents, Personal Information includes any information that is identifiable to your household.
Information We Collect About You and How We Collect It
When you access the Website for informational purposes and do not use Coin Cafe Services or register an Account, we may automatically collect information on or through our Website from you that includes:
- Usage details such as IP addresses and information collected through cookies, web beacons and other tracking technologies;
- Records and copies of your correspondence (including e-mail addresses), if you contact us; or
- Your search queries on the Website.
Service Users and Account-Holders
In addition to the information above that we collect when you access the Website, we request and retain several types of information from and about Service Users and Account-holders for purposes of understanding and verifying the identity and activity of such individuals as required by governing U.S. laws and regulations. The information collected includes:
- Contact information, such as your full legal name, mailing and physical address, telephone number, and email address, and any other identifier by which you may be contacted online or offline;
- Financial information, such as bank Account numbers, credit card or debit card numbers, related billing addresses and transaction information relating to your transactions on the Website, and virtual currency Account and wallet information;
- Government identification numbers, such as your social security number or a state-issued identification number;
- Government-issued photo identification such as a driver’s license or passport;
- Biographic or demographic information, such as your date of birth, gender, occupation, employment status and any other information you choose to provide about yourself;
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website and Coin Cafe Services or when requesting further services. We may also ask you for information when you report a problem with our Website or Coin Cafe Services;
- Records and copies of your correspondence (including e-mail addresses), if you contact us;
- Your search queries on the Website; and
- Information about your internet connection, the equipment you use to access our Website and usage details.
Service Users and Account-Holders
From business entities that use our Services or register an Account, we will collect information about your business that includes identifying your business entity name, business owners and beneficial owners, and providing entity formation documents and tax identification numbers. Business owners must provide the Personal Information required for individual Account-holders. We collect this information for purposes of understanding and verifying the identity and activity of such business entities as required by governing U.S. laws and regulations.
When We Collect This Information
We collect information about you at various times, which includes:
- directly from you when you provide it to us upon using a Service or registering an Account;
- automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies, which is collected when you visit the Website and use Coin Cafe Services; and
- from third parties, for example, credit bureaus or data aggregation services, upon using our Services and during the term you maintain an open Account.
Information We Collect through Automatic Data Collection
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about the computer or mobile device you use to access the Website and Coin Cafe Services, and your browsing actions and patterns, including:
- Details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website;
- Information about the transactions you complete using Coin Cafe Services, including the amount of funds associated with a transaction and other transaction information; and
- Information about your internet connection, including your IP address, operating system and browser type.
The information we collect automatically may include Personal Information, however we may maintain it or associate it with Personal Information we collect in other ways, or receive from third parties. We do this because it helps us to improve our Website and to deliver a better, and more personalized service, including enabling us to:
- Estimate our audience size and usage patterns;
- Store information about your preferences, which allows us to customize our Website according to your individual interests;
- Speed up your searches; or
- Recognize you when you return to our Website.
- Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail, and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
How We Respond to Do Not Track Signals
While your internet browser may be configured to send a Do Not Track request, we do not respond Do Not Track requests. We will still collect and use your browsing data to improve security, provide content, services, and to generate reporting statistics.
Information We Collect from Other Sources
We may also obtain information from other sources and combine that with information we collect through Coin Cafe Services. For example, we may collect nonpublic Personal Information about you from third parties, including identity verification services. However, we will not re-disclose or reuse your Personal Information that we’ve received from a third-party, unless we are disclosing the information:
- To the affiliate from which we received the information;
- To our affiliates who are permitted to use the information in accordance with this Policy; or
- To contractors, service providers and other third-parties we use to support our business, and who are bound by contractual obligations to keep Personal Information confidential, and use it only for the purposes for which we disclose it to them.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How We Use Your Information
We use information that we collect about you or that you provideto us, including any Personal Information:
- To present our Website and its contents to you;
- To provide you with Coin Cafe Services and customer support;
- To process transactions and send notices about your transactions;
- To manage and provide you with notices about your Account including technical notices, updates, security alerts, and support and administrative messages;
- To carry out our legal and regulatory obligations;
- To notify you about changes to our Website or any products or services we offer or provide through it;
- To allow you to participate in interactive features on our Website; or
- For any other legitimate business purpose with your consent.
Disclosure of Your Information
We may disclose aggregated information about our users, however, we will not disclose any information to a nonaffiliated third party that identifies an individual and their bank Account, credit card, or virtual currency Account numbers for use in telemarketing, direct mail marketing, or any other marketing.
We may disclose Personal Information that we collect or that you provide, as described in this Policy:
- To our subsidiaries and affiliates.
- To contractors, service providers and other third parties we use to support our business, and who are bound by contractual obligations to keep Personal Information confidential, and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Coin Cafe’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by Coin Cafe about our Website users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your Personal Information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Coin Cafe, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We do not otherwise share or disclose your Personal Information to any nonaffiliated third parties outside of the limitations provided above. Coin Cafe is not considered a consumer reporting agency and will not resell, share, or disclose your personal credit information to any non-affiliated third party.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
- We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose to not have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
Do Not Sell My Personal Information
Coin Cafe does not sell any Personal Information you provide to us or that we receive from a third-party in connection with your use of Coin Cafe Services or an Account, and treats your information as though you have opted-out of such sales under California law.
Accessing, Correcting and Deleting Your Information
You can review and change your Personal Information by logging into the Website and visiting your settings page.
You may also send us an e-mail at [email protected] to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your Account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Service.
Certain legal and regulatory recordkeeping retention requirements apply to your information. For example, depending on the type and nature of the record, the federal Bank Secrecy Act requires a minimum retention period of five (5) years for records relating to Accounts and transactions. Records related to the personal identification of Service users and Account-holders must be maintained for a period of five (5) years after the account is closed or deleted. The New York Department of Financial Services further requires that all books and records in connection with virtual currency business activity shall be preserved for a period of at least seven (7) years from the date of creation.
Your California Privacy Rights
The California Consumer Privacy Act and California Civil Code Section § 1798.83 permit users of our Website who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, during the preceding 12 months. You have the right to request certain information from Coin Cafe, including the sources from which we have collected your Personal Information, specific pieces of information we have collected about you, and the third-parties with which we have shared your information. To make such a request, please send an e-mail to [email protected], write us at: CCI Holdings, Inc., P.O. Box 220372, Brooklyn, NY 11222, or call us at 1-347-454-2646.
In response to you exercising your privacy rights under the Act, Coin Cafe will not discriminate against you, deny you services, charge different prices, or provide a different quality of service.
Individual Rights of European Union Residents
Residents of the European Union assume individual privacy rights under the General Data Protection Regulation (“GDPR”). Coin Cafe is considered a data controller in that it collects data and information from all Website users, Service users and Account-holders, and controls the actions and purpose of the data usage.
All data collected from you is processed by Coin Cafe for the reasons explained above under How We Use Your Information. Additionally, we are required to comply with federal and state laws, such as those in the Bank Secrecy Act and enforced by the New York Department of Financial Services that mandate the collection, verification, recording and reporting of certain personal information. Third-parties may be utilized to assist us with conducting certain business functions, such as verifying your identification information and documents. However, Coin Cafe remains in control of your data and information and how it is used, as specified in contractual agreements made with such third-parties. Personal Information may be transferred internationally while under the control of Coin Cafe as a condition or requirement of fulfilling a business obligation as described within this Policy.
Residents of the European Union have the following rights, under the GDPR, which they can make use of by sending a request by sending an email to [email protected] or via the services support channel for consideration under applicable law:
- The right of users to withdraw their consent to the processing of Personal Information at any time and for any reason. The user’s withdrawal of consent shall not affect the lawfulness of Coin Cafe’s processing of user information prior to withdrawal of consent;
- The right to request a copy of the user’s Personal Information maintained by Coin Cafe. The user’s right to access this information will only be affected when the rights of those other than the user making the request would be infringed upon or when the right to access this Personal Information unduly burden, financially or otherwise, Coin Cafe;
- The right to request erasure of Personal Information in certain circumstances including when the information is no longer necessary in relation to the purposes for which it was connected, the user having withdrawn consent, or during instances where information was collected during unauthorized access and the legitimacy of the activity has come into question;
- Users have the right to object to the processing of Personal Information when users contest the accuracy of Personal Information that Coin Cafe processed, when the processing of Personal Information is unlawful and erasure of Personal Information is not an option, when Coin Cafe no longer requires Personal Information for the processing of transactions, but rather for the Personal Information to be used for legal purposes, and the user has objected to the processing, pending the verification whether the legitimate grounds Coin Cafe’s processing override the user’s rights;
- The right to object to the processing of Personal Information, as permitted by applicable law, whenever processing is based off of the user’s consent;
- The right to receive notification correction, restriction, erasure or modification to user’s Personal Information;
- The right not to be subjected to automated decision-making processes including, but not limited to profiling;
- The right to lodge a complaint with Coin Cafe if the user believes we have infringed upon their rights. In such an event, we encourage the user to contact us first at [email protected] so that we can attempt to resolve the issue informally.
Safeguarding Your Information
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Your Personal Information will be stored for the duration of your relationship with Coin Cafe, and for a period of time thereafter as required by U.S. law for the type and purpose of the information provided. Any payment transactions, social security numbers, and bank Account access information will be encrypted using TLS technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We will never ask you for your password when contacting you, and a password reset will always be required if you cannot recall the current password. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Consent to Processing Outside Home Country
If you do not agree with these terms, then do not access, browse, or register for the Website or any services offered through the Website. If you choose not to provide us with certain information required to provide you with various services offered on our Website, you may not be able to establish an Account and we may not be able to provide you with those services.
CCI Holdings, Inc. P.O. Box 220372, Brooklyn, NY 11222