This policy is compiled in accordance with the legal requirements of the Hungarian legislation in the name of Coinerz Kft. (FullCoin). The policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Coinerz Kft. is registered with the Hungarian National Authority for Data Protection and Freedom of Information (NAIH). The registration number of Coinerz Kft. is NAIH-140702/2018.
By using our site, you consent to such processing and you warrant that all data provided by you is accurate.
Coinerz Kft. ("we" or "us" or FullCoin) are committed to protecting and respecting your privacy.
This policy together with our Terms and Conditions and any other documents referred to in it sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting this website you are accepting and consenting to the practices described in this policy.
For the purpose of the Act CXII of 2011 on Informational Self-Determination and Freedom of Information, the Data Controller is Coinerz Kft. of H-2330 Dunaharaszti, Jendrassik György str. 6.
PRINCIPLES OF DATA MANAGEMENT
The Data Controller undertakes to handle the personal data entrusted to it in accordance with all applicable laws, to comply with the statutory data management principles, to comply with the purpose limitation, minimization and security obligations.
It also undertakes to respect the right of information of self-determination of the data and does not disclose personal information to a third party except for statutory obligations.
The principles of data protection serve as guidelines for the company's data management in order to fully comply with the legal requirements for the management of personal data of customers.
The Data Controller is responsible for compliance with the principles and, if necessary, must be able to demonstrate the legality of his or her data management.
Personal data can only be considered as a natural person’s data.
Personal data can only be processed for a predetermined purpose, to the extent and for the duration necessary to achieve the goal.
The management of personal data shall be based on a statutory mandate or - lacking this - the voluntary contribution of the relevant and appropriate information.
In accordance with the principle of fair data management, a data subject may never become a mere subject of a process of personal data management, with respect to the provision of the personal data of the person concerned, with respect to the personal data of the data subject, or to any other person.
According to the data quality principle, the data processed must be accurate, complete and current in accordance with the purpose of data management.
According to the security principle, the data should be protected by reasonable measures appropriate to the state of the art against unauthorized access, alteration, unauthorized disclosure, injury, and destruction.
The fact, location, purpose, data controller and data management policy of the data management must be public.
As a result of the personal participation principle, the person concerned may know, correct, supplement, or delete relevant information in accordance with the relevant legal requirements.
The principles of data management and the obligation to observe them apply to both the Data Controller and subject of data.
LEGAL BASIS AND PURPOSE OF DATA MANAGEMENT
Legal basis of data management:
Purpose of data management:
The purpose of data management is on one side to help carrying out buy and sell transactions of digital currencies, on the other side data handling and contacting users related to the support, operation and customer service activities throughout the process.
The handling of personal data serves to fulfill the legal obligations in order to prevent the financing of money laundering and terrorist, and, to this end, to cooperate with the authorities, too.
According to our statutory obligations our company cooperates with the authorities and in this connection handles all the data related to the transactions to the authorities at need.
Our Company does not pass on or make available the data it manages for marketing purposes to a third party.
PERSONAL DATA MANAGED BY US
In order to minimize the personal information we receive from our clientele - basically as determined by the amount of transaction - we have created 3 different levels and request personal information from our Clients depending on the levels. You can find out more about these levels in our AML/KYC Policy.
Data that we may require to identify clients:
active contact phone number
active contact email address
bank account number
address (Country, County, City, Address, Postal Code)
a high-resolution scanned copy of a current valid EU or non EU Passport issued by the government
a high-resolution scanned copy of a current valid National ID card issued by the government
a high-resolution scanned copy of a current valid Driving License issued by the government
a high resolution scanned copy of a photo of the client as she/he holds 2 of the ID documents mentioned above and also a paper with the text written on it that was sent by us prior
Recent Utility Bill (received via post) — Gas, Electricity, Water, Telephone
Bank Statement (received via post)
Other might be recorded data:
date and place of birth
date and time of visiting our website
IP address of the visitor/user
the type of browser of the visitor/user
the Bitcoin wallet addres of the user
the bank account of the user
The owner of the data is responsible for the accuracy and credibility of the data.
It is in your interest and obligation to disclose your changed personal data with the Data Manager.
The data operator or the service provider company shall not be liable for any disadvantages resulting from the non-fulfillment of the above.
We also may process the following data about you:
Information you give to us. You may give us information about you by filling in forms on www.fullcoin.eu ("our site") or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number.
Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
The www.fullcoin.eu website also contains links to external servers (not managed by Coinerz Kft.), pages accessible on these links may place their own cookies or other files on the computer, collect data, or request personal information. For these purposes, Coinerz Kft. excludes all liability.
USES OF DATA
We use information held about you in the following ways:
Information you give to us. We will use this information to:
Carry out our obligations arising from any contracts entered into between you and us, and to provide you with information, products and services that you request from us;
Provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
Provide you with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer we will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way please tick the relevant box situated on the form on which we collect your data;
We notify you about changes to our service;
Ensure that content from our site is presented in the most effective manner for you and for your computer;
Information we collect about you. We will use this information:
to administer our site and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
DISCLOSURE OF DATA
We may share your personal information with any member group, which means our subsidiaries, our ultimate holding company and subsidiaries.
We may share your information with selected third parties including:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Coinerz Kft. or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area ("EEA"). It may be processed by a staff member operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in amongst other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
Our host provider is Amazon Web Services, Inc. at the moment.
THE PRACTICE OF SOME TYPICAL DATA MANIPULATION
Personal record of user’s data
Copying the user’s data
The personal data file may be copied if this is unavoidable when examining all other reasonable alternatives, and the copy must be made so that the copy only records the most necessary data.
The Data Controller must be fully acquainted with the purpose of making a copy and must give written consent to it.
Using cameras (web) and recording phone calls
Over a certain AML level our company may initiate a personal contact in the form of a digital call, which can be used to make a video. Recorded video clips are stored for up to 60 (sixty) days.
The legal basis for the recording of telephone conversations is not the voluntary consent of the concerned party, but a statutory delegation: a. Of the Consumer Protection Act 17 / B. Paragraph (3) also stipulates that telephone communications between the customer service and the consumer must be recorded by voice.
If our User does not contribute to fixing the telephone conversation with him/her, our helpdesk service cannot be used for any of our automated services.
The purpose of recording telephone conversations is to protect the data subjects and Data Controller's rights and to guarantee ex post verification.
When recording phone conversations, we store the following data:
phone number, call time, voice recording of recorded conversation, personal information provided during conversation.
We keep the phone conversations for 5 years. The soundtracks are made available by phone number and date of conversation.
In the case of requested data, the recorded audio material will be provided on a data carrier according to the following procedure: the person in question asks for the recording of the recorded conversation, which in the application indicates the telephone number of the device used for the conversation or the time of the conversation (minimum by year, month and day).
To a written request:
please attach a data medium (such as a writable CD),
please indicate the password in the application that is intended to be used for encryption,
and please indicate the address to which the information service is to be sent.
The written request will be sent to the registered office of the Company, within 15 days from the receipt of the request, the Company will examine the legality of the information service.
If there is no legal impediment to the provision of information, the Company will send the requested data to the applicant by post, registered mail.
If the information can’t be met, the reason for rejecting the request is returned to the applicant in the unchanged forM.
PROVIDE INFORMATION ON DATA MANAGEMENT, DELETE AND BLOCK DATA
According to the law, the data IN subject may apply to the Data Controller:
Information on handling personal data
At the request of the person concerned, the Data Controller shall provide information about the data management that he or she is handling by or on behalf of the person concerned.
The Data Controller shall provide the information in writing in the shortest possible time, but not later than 25 days, in an understandable form, at the request of the person concerned.
In the event of denial of information, the Data Controller informs the person concerned of the possibility of a court appeal and of the National Data Protection and Information Authority (hereinafter referred to as "the Authority").
Correction of personal data
If the personal data does not comply with the reality and the personal data corresponding to the reality is available to the data controller, the personal data will be corrected by the Data Controller.
Deleting or blocking personal information, except mandatory data management
Personal data must be deleted, if:
it is illegal to handle it;
the person concerned requests to delete it;
is incomplete or incorrect - and this condition cannot be legally remedied - provided that the termination is not excluded by law;
the purpose of data management has ceased or the statutory deadline for data storage has expired;
it is order by the Court or Authority.
Instead of being deleted, the Data Controller locks out personal data if such request is needed, or if, on the basis of the information available to concerned person, it is assumed that deletion would undermine the legitimate interests of the data subject.
Personal data so locked up can only be handled as long as there is a data management target that excludes the deletion of personal data.
The Data Controller provides a regulatory request based on law, in which the Authority indicates the data requested and the purpose of the data management, to the extent appropriate to the purpose of the request.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The Hungarian Act CXII of 2011 on Informational Self-Determination and Freedom of Information gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.
Act V. of 2013 on Civil Code
Act XLVII. of 2008 on Unfair Commercial Practices Against Consumers
Act CXXXVI. of 2007 on Anti-money Laundering and Prevention of Terrorist Financing
Act CLV. of 1997 on Consumer Protection
Act CVIII. of 2001 on E-commerce Services and Information Society Services;
Act CXII. of 2011 on Informational Self-Determination and Freedom of Information.
In case of a request, question, proposal or complaint in regards of data management you can contact the representative of the Data Handler of the Company via the following contact details: [email protected].
You can also turn to the Hungarian National Data Protection and Freedom of Information Authority with any of your complaints in regards of data handling:
Hungarian National Data Protection and Freedom of Information Authority contact details:
Address: Hungary 1125 Budapest, Szilágyi Erzsébet fasor 22/c.
Mailing address: Hungary 1530 Budapest, Pf. 5.
Phone: +36 (1) 391-1400 Fax: +36 (1) 391-1410
Email: [email protected]