Privacy Policy Last updated: 24/02/2024

We, referred to as “Us” or “Our”, are dedicated to protecting your Personal Data and maintaining your privacy.

This Privacy Policy has been crafted to enlighten you about how We handle, collect, store, and utilize the information you provide in relation to the website (the “Website”).

We are committed to upholding the following principles:

•To ensure transparency in the collection and processing of your Personal Data:

We emphasize keeping you fully informed, allowing you to make educated decisions regarding the use of your Personal Data on our Website or when engaging in trading with an external trading platform. To this end, we employ various strategies and methods to provide you with relevant information on how your Personal Data is processed, ensuring that this information is presented accurately and promptly.

Furthermore, if it is necessary for you to receive specific information, We will provide it to you in a timely and suitable manner.

We are also eager to address any inquiries you may have and to offer any clarifications you might need, subject to legal constraints. For this purpose, you can contact Us by sending an email to the following address: support@

•To process your Personal Data solely for the purposes outlined in this Policy:

The purposes for which We may process your Personal Data include, among others, to make the Website accessible to you and

provide you with a link to third-party trading platforms (the “Services”), to enrich the user experience on the Website, enhance the Services (including the Website), safeguard Our rights and interests, conduct business and administrative activities that support the provision of the Services to Website users, and/or comply with any legal and/or regulatory obligations.

Additionally, We will handle Personal Data about you to better understand your unique needs and preferences.

• To allocate substantial resources to honor your rights regarding Personal Data about you:

We commit significant resources to empower you to exercise your rights as a data subject. Therefore, you may contact Us anytime to review Personal Data about you, request amendments, deletion, restrict its use for certain purposes or overall, or have it transferred to you or a third party. We will comply with your requests in accordance with the law.

•To safeguard Personal Data about you:

While We cannot guarantee absolute protection of the Personal Data about you, We assure you that We use and will continue to use a comprehensive range of methods and measures aimed at securing the Personal Data about you.

Our Comprehensive Privacy Policy

1. The Scope?

This Policy outlines the type of Personal Data the Company collects about individuals, and how it collects, utilizes, shares with third parties, secures, processes it, etc.

In this Policy, “Personal Data” pertains to any information related to an identified or identifiable natural person. An identifiable natural person is someone who can be identified, directly or in conjunction with additional information that We possess or have access to.

In this Policy, the “processing” of Personal Data involves any operation or set of operations carried out on Personal Data, including the collection, recording, organization, structuring,

storage, adaptation, modification, retrieval, consultation, use, transmission disclosure, dissemination, or any other form of making available, alignment or combination, restriction, erasure, or destruction of Personal Data.

Our Services are crafted for a general audience and are not designed for individuals under 18 years of age. We do not intentionally gather or solicit data from anyone under the age of 18, nor do we knowingly permit such individuals to use our Services. Should we discover that we have collected data from a minor, we will promptly take appropriate measures to remove such data.

2. When Do We Collect Personal Data About You?

We gather Personal Data about you whenever you engage with the Services, utilize the service channels, or navigate the Website. At times, you will voluntarily supply Us with Personal Data, and at other times, We will collect Personal Data by observing and analyzing your interaction with Our Services and/or service channels or by receiving your data from our third-party collaborators.

3. No Obligation To Provide Personal Data To Bit App And Its Implications

You are not required to furnish Us with any Personal Data. However, in some cases, withholding such Personal Data may prevent Us from offering you the Services, limit your access to the Website, and/or result in the improper functioning of the Services and the Website.

4. What types of Personal Data do We collect? Personal Data We collect during each visit to the Website:

This information includes online activity logs, traffic details (such as, but not limited to, IP address, access time, access date, pages visited on web and mobile, language used, software crash reports, and browser type), and information about the device used. Some of this information may not be personally identifiable, and thus may not be classified as Personal Data.

Personal Data We receive from you: any Personal Data you willingly provide to Us when engaging with a third-party trading platform through Bit App.

Personal Data You provide for submission to third-party platforms for trading purposes: This information includes your full name, telephone number, and email address.

5. The Purposes of Processing Personal Data and Their Legal Basis

Our Company processes your Personal Data for one or more of the purposes outlined in this section and in accordance with the applicable legal basis.

The Company will only process your Personal Data if there is a legal basis for doing so. The legal bases on which the Company may process your Personal Data are as follows:

  • You have provided consent for the processing of your Personal Data for one or more specific purposes. This pertains to instances where you intentionally provide your details through the Website for submission to third-party trading platforms.
  • Processing is necessary for the legitimate interests pursued by the Company or a third party. For example, to enhance our Services or for the exercise or defense of legal claims.
  • Processing is necessary to comply with a legal obligation to which the Company is subject.

If you require further information on how the processing of your Personal Data serves the legitimate interests of our Company or a third party, please feel free to contact us via email at any time.

Below, we provide a summary of the reasons we might process your Personal Data, along with the legal grounds for such activities:

Purpose Legal Basis
1

To facilitate sharing your details with third parties at your request for engaging in digital and trading activities.

We might gather your Personal Data to pass it on to third parties if you expressly request us to do so.

You have provided consent for processing your Personal Data for one or more specified reasons.
2

To address your inquiries, requests, and/or concerns

Processing your Personal Data is necessary to address any questions you have about using our Services.

Processing is essential for fulfilling the legitimate interests of the Company or a third party.
3

To fulfill any legal duties or comply with judicial or administrative mandates

At Bit App, we handle your Personal Data to meet our legal responsibilities effectively.

This processing is essential to meet a legal requirement applicable to the Company.
4

To enhance our services

We may utilize your Personal Data to refine our services. This process might include analyzing crash logs or any other malfunction reports related to our services.

Processing is necessary for the pursuit of legitimate interests by the Company or a third party.
5

To prevent fraud and misuse of our services

Processing is necessary for the pursuit of legitimate interests by the Company or a third party.
6

To conduct and sustain various activities that support our service offerings

These activities encompass back-office functions, business development initiatives, strategic decision-making processes, oversight mechanisms, and more.

Processing is essential for advancing the legitimate interests of the Company or a third party.
7

To conduct analyses, including statistical assessments

We employ a variety of analytical techniques (including statistical methods) to make informed decisions on various matters.

Processing is essential for advancing the legitimate interests of the Company or a third party.
8

To safeguard Our and third parties' interests, rights, and assets, including initiating, exercising, or defending legal claims

We may process your Personal Data to protect Our interests, rights, and assets, or those of third parties, in compliance with any applicable law, regulation, or agreement, including Our terms, conditions, and policies.

Processing is essential for advancing the legitimate interests of the Company or a third party.

6. Transfer Of Personal Data To Third Parties

At Bit App, we may share your Personal Data with third-party service providers who assist us in delivering our services. This includes entities offering storage solutions, hosting services, IP address details, user experience insights, as well as research, analytical, technical, and diagnostic support.

Additionally, should you request, we can transfer specific Personal Data about you to external trading platforms. In these scenarios, the data you provide will be shared with these third parties, and they will handle your Personal Data according to their own privacy guidelines. Your Personal Data might be shared with several different trading platforms.

Bit App might also share your Personal Data with our affiliated entities and business collaborators. These partnerships enable us to enhance and elevate the quality of services and products we offer our users.

Your Personal Data may be disclosed to governmental, local, official, and regulatory bodies if required, particularly to safeguard our interests and those of third parties, including initiating, pursuing, or defending legal actions.

Moreover, we may disclose your Personal Data to prospective buyers, investors, or lenders to Bit App, and/or any affiliated company within our corporate group. This disclosure may occur in transactions such as asset sales, mergers, reorganizations, consolidations, or bankruptcies involving Bit App or any related company.

7. Cookies and Third-Party Services

Bit App may employ certain third-party services, including analytics firms or advertising providers on our website, which might use cookies or other tracking technologies. These practices are governed by their respective policies.

A cookie, a small text file, may be installed on the device you use to visit or access the Website. These cookies help collect information about you and your behavior to

enhance your user experience, recall your preferences and settings, and tailor products and services that might pique your interest. Additionally, cookies are utilized to gather statistics and perform analytics.

We may employ both session cookies, which are temporarily downloaded to your device and remain until you close your web browser, and persistent cookies, which stay on your device after you stop browsing the Website, assisting in recognizing you as a returning visitor when you revisit the Website.

Categories of cookies:

The cookies we utilize are categorized by their functionality, as follows:

Type of Cookie Purpose Additional Information
Strictly Necessary Cookies

These cookies are essential for enabling you to navigate the Website and access the features you've requested. They are used to deliver the content, products, and services you have asked for from Bit App.

Such cookies are crucial in assisting your device to download or stream information, enabling you to move around the Website, use its features, and revisit pages you've previously accessed.

These cookies collect Personal Data about you, like your username and last login date, identifying you as logged into the Website.

These cookies disappear when you shut down your web browser (session cookies).

Functionality Cookies These cookies help us identify you upon your return to the Website and enable us to remember your selections and preferences. These cookies persist even after your web browser is closed, and remain active until they reach their designated expiry date.
Performance Cookies These cookies gather aggregated data concerning the Website's performance and help us test and enhance it, ensuring a superior user experience. They also allow us to perform analytical tasks on the Website.

These cookies gather anonymous data that does not pertain to any identifiable individual.

These cookies have varied lifespans; some are erased when you close your browser, while others remain indefinitely.

Managing and Deleting Cookies

You have the ability to modify your browser settings to block and erase some or all cookies. Below are links with instructions for some of the most commonly used web browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

Please be aware, though, that doing so may cause some or all of the features and functions of the Website to not operate as expected.

ONLINE TRACKING NOTICE

CURRENTLY, THIS SERVICE DOES NOT RECOGNIZE DO-NOT-TRACK SIGNALS.

8. Retention Of Personal Data About You

Bit App will retain your Personal Data for as long as necessary to achieve the purposes outlined in this Policy or for a longer duration if required by applicable laws, regulations, policies, or orders.

We may share your information with third-party trading platforms for a 12-month period, and with your consent, we may extend this for an additional 12 months.

To ensure Personal Data about you is not kept longer than necessary, we periodically review the retained data to determine if any can be deleted.

9. Transfers of Personal Data To A Third Country Or An International Organization

Your Personal Data may be transferred to another country (i.e., jurisdictions different from where you reside) or to international organizations. In such cases, Bit App will implement appropriate measures to ensure your Personal Data is protected, ensuring that data subject rights and effective legal remedies are accessible.

If you are a resident of the EEA (European Economic Area), please note that these safeguards and protections will be in place if any of the following conditions are met:

  • The transfer is directed to a third country or an international organization deemed by the EU Commission to offer a satisfactory level of protection for Personal Data transferred under Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council dated 27 April 2016 (the "GDPR").
  • The transfer adheres to a legally binding and enforceable agreement between public authorities or bodies in line with Article 46(2)(a) of the GDPR; or
  • The transfer complies with standard data protection clauses sanctioned by the EU Commission under Article 46(2)(c) of the GDPR. You can review the clauses approved by the EU Commission at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

Should you wish to inquire about the protective measures employed by Bit App to secure the Personal Data transferred to a third country or an international organization, please send an email to: support@

10. Safeguarding Your Personal Data

We deploy suitable technical and organizational measures to maintain an appropriate security level for Personal Data, considering the risks involved in processing, particularly from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data that is transmitted, stored, or otherwise processed.

While we strive for error-free performance concerning the privacy of your Personal Data, we cannot assure it, nor can we be held liable for any indirect, incidental, consequential, or punitive damages related to the use or disclosure of your Personal Data, including, but not limited to, unauthorized third-party access, transmission errors, or other factors beyond our reasonable control.

Due to legal or other obligations beyond our control, we may be compelled to transfer your Personal Data to third parties,such as public authorities. In these scenarios, our ability to control the protection level of your Personal Data by these third parties is limited.

Transferring Personal Data over the internet carries inherent security risks. As a result, Bit App cannot fully guarantee the security of your Personal Data when it is transferred over the internet to us.

11. Links To Websites of Third Parties

The Website might offer links to third-party websites and/or applications. Bit App does not have control over these sites and applications or their handling of your Personal Data, and we cannot be held accountable for them or their privacy and data protection practices. This Policy does not cover any actions conducted through such websites and/or applications.

We advise you to thoroughly review the privacy policies of any third-party websites and/or applications before engaging with them or sharing any Personal Data.

13. Your Rights in Respect Of The Personal Data About You

You generally have the right to ask us to confirm if we are collecting your Personal Data, to review it, correct any inaccuracies, and request the deletion of data no longer needed by Bit App. You may also limit your consent to specific types of processing of your Personal Information.

If you are an EEA resident, please read this section below:

As an EEA resident, you have the following rights regarding your Personal Data. To exercise these rights, you may send a request to the following email address:

Right of access

You have the right to receive confirmation from Bit App about whether your Personal Data is being processed, and if so, access the Personal Data and the followinginformation: (1) the objectives of the processing; (2) the types of Personal Data involved; (3) the recipients or groups of recipients who have received or will receive the Personal Data, particularly those in countries outside the European Economic Area (EEA) or international organizations; (4) if feasible, the planned duration for storing the Personal Data, or, if not feasible, the criteria used to establish that duration; (5) the existence of the right to request from the Company the correction or deletion of Personal Data or restriction of its processing, or to object to such processing; (6) the right to file a complaint with a supervisory authority; (7) if the Personal Data is not collected from you, any available information about its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the suitable safeguards in place for the transfer.

The Company will provide a copy of the Personal Data being processed and may impose a reasonable fee for any additional copies requested by you. If your request is made electronically, and unless you request otherwise, the information will be provided in a commonly used electronic format.

The right to receive a copy of the Personal Data must not infringe upon the rights and freedoms of others. Therefore, if the request negatively impacts others' rights and freedoms, the Company may choose not to fulfill your request or do so in a limited capacity.

Right to rectification

You are entitled to request from the Company the correction of any inaccurate Personal Data concerning you. Considering the objectives of the processing, you have the right to have incomplete Personal Data about you completed, potentially through a supplementary statement.

Right to erasure

The following conditions apply: (a) the Personal Data is no longer needed for the purpose it was initially collected or otherwise processed; (b) you revoke your consent on which the processing is based, and no other legal grounds exist for the processing; (c) you object at any time, on grounds related to your specific situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by us or by a third party, and there are no compelling legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) thePersonal Data has been unlawfully processed; or (f) the Personal Data about you needs to be erased to comply with a legal obligation in European Union or Member State law applicable to the Company.

This right is not applicable to the extent that processing is necessary (a) to fulfill a legal obligation requiring processing by European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise, or defense of legal claims.

Right of Restriction of Processing

You have the right to request that the Company restrict the processing of your Personal Data if any of the following conditions apply: (a) you dispute the accuracy of the Personal Data, allowing the Company time to verify its accuracy; (b) the processing is unlawful and you oppose the deletion of your Personal Data, preferring instead to limit its use; (c) the Company no longer requires your Personal Data for processing purposes, but you need it to establish, exercise, or defend legal claims; (d) if processing your Personal Data is necessary for the Company's or a third party's legitimate interests, unless we can demonstrate compelling legitimate grounds that outweigh your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims; or (e) if your Personal Data is processed for direct marketing purposes, including profiling, insofar as it relates to such direct marketing.

If the processing of your Personal Data has been restricted at your request, such Personal Data, aside from storage, will only be processed with your consent or for the establishment, exercise, or defense of legal claims, or to protect the rights of another individual or legal entity, or for reasons of significant public interest in the European Union or a Member State.

Right to Data Portability

You have the right to receive your Personal Data, which you've provided to the Company, in a structured, commonly used, and machine-readable format. You are also entitled to transfer that data to another entity if the processing is based on your consent or a contract you're part of, and if the processing is automated.

When exercising your right to data portability, you can arrange for your Personal Data to be transferred directly from the Company to another entity, where it is technically feasible. This action does not interfere with your or the Company's rights regarding data deletion. Additionally, this right should not adversely affect the rights and freedoms of others.

Right to Withdraw Consent

You may withdraw your consent for us to process your Personal Data at any time. This will not impact the legality of processing carried out before your consent was withdrawn.

Right to Object

You are entitled to oppose the processing of your Personal Data at any time, especially if it pertains to your particular circumstances, and when processing is based on the legitimate interests of the Company or a third party. This includes any profiling linked to these interests. If you object, we will cease processing your Personal Data unless we can present compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

You also hold the right to object to the processing of your Personal Data for direct marketing purposes at any time, including any related profiling.

Right to lodge a complaint with a supervisory authority

You have the right to file a complaint with a supervisory authority appointed by a Member State to safeguard the fundamental rights and freedoms of individuals regarding the processing of Personal Data within the European Union.

Your rights concerning Personal Data as described in this section 13 may be limited by European Union or Member State law applicable to the Company.

We will provide the information requested according to your rights mentioned in this section 13 without undue delay and, in any case, within one month of receiving the request. This period may be extended by two additional months if necessary, considering the complexity and number of requests. We will notify you of any such extension within one month of receiving your request, along with the reasons for the delay.

The information requested as per your rights in this section 13 will be provided free of charge unless otherwise stated in this section 13. Where requests are manifestlydeemed unreasonable or overly frequent, especially if they occur repeatedly, we reserve the right to either (a) impose a fair fee, considering the administrative costs associated with providing the requested information or communication, or (b) decline to comply with the request.

Bit App may request additional information to verify your identity to ensure compliance with your rights as outlined in this section 13, particularly if we have reasonable doubts regarding the identity of the individual making the request.

12. Amendments to This Policy

We may periodically update the terms of this Policy. When we do so, we will notify you by posting the revised Policy on the Website. Additionally, if there are significant changes, we will make every effort to inform you through communication channels we consider appropriate and by posting a notice on the Website. Unless specified otherwise, all changes will take effect upon the publication of the updated Policy on our Website.