Privacy policy

 

SCOPE

This Privacy Policy (together with our Terms & Conditions) governs our collection, processing and use of our Users’ and visitors of our Site’s Personal Information and explains what you can expect from us and what we need from you in relation to your Personal Information.

Please note that ROKKEX complies with the principles of GDPR. The six overall guiding principles are:

  • Lawfulness, transparency and fairness;
  • Purpose limitation;
  • Data minimisation;
  • Accuracy;
  • Storage limitation;
  • Confidentiality and integrity.

Please read this carefully as this Privacy Policy is legally binding and applies to any ROKKEX Exchange Services regardless of how you access or use them, including through mobile devices.

 

DEFINITIONS

Digital Asset means a digital representation of value (also referred to as “cryptocurrency”, “virtual currency”, “digital currency”, “crypto token”, “crypto asset” or “digital commodity”), such as Bitcoin, XRP or Ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.

Personal Information or Personal Data means any information relating to you, as an identified or identifiable natural person, which identifies you personally or which may help us to identify you including but not limited to your name, an identification number, location data, address, email address or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.

Data Subject means an identified or identifiable person (our User).

Data Controller means a company which determines the purposes and means of personal data processing.

Data Processor means a company which processes personal data on behalf and upon instructions of the Data controller.

Personal Data Processing means any operation or set of operations performed on Personal Data including but not limited to collection, storage, use, disclosure, erasure of Personal Data.

ROKKEX, we, us, our refers to ROKKEX OÜ and its wholly owned subsidiaries (also referred to collectively as ROKKEX).

ROKKEX Account means a user-accessible account offered via the ROKKEX Exchange Services where Digital Assets are stored by ROKKEX.

ROKKEX Exchange Services means ROKKEX-branded websites, applications, services or tools operated by ROKKEX group companies.

Other capitalized terms, not defined above, have the meanings as defined in the Terms & Conditions and the applicable data protection legislation (namely, the General Data Protection Regulation 2016/679 as of April 27, 2016).

Where the context so admits words denoting the singular shall include the plural and vice versa.

 

WHO IS ROKKEX

ROKKEX is a company registered in Estonia. Our registered office is at Harju maakond, Tallinn, Kesklinna linnaosa, Narva mnt. 5, 10117 Estonia.

ROKKEX was established in 2019 as security-first crypto-to-crypto, crypto-to-fiat multi-functional exchange platform for beginners and advanced traders.

 

INFORMATION WE MAY COLLECT ABOUT YOU

ROKKEX may collect your Personal Data if you use ROKKEX and open a ROKKEX Account or perform any Transactions on the Platform for the purpose of provision of service(s) to you in accordance with our Terms & Conditions. Please note that if you refuse to share your Personal Data for this purpose we will not be able to provide our services to you.

Personal Data which ROKKEX collects about you may include:

  • Name;
  • Photographic identification;
  • Details from your identity documents (such as a driver’s license, passport), number of the document, date of issue and expiration, photographic identification, address, etc.;
  • Address;
  • Phone number;
  • Email address;
  • IP, Browser and Operating System information, geolocation details;
  • Banking details including account numbers and payment card data;
  • Date of birth;
  • Employment details;
  • Trades; and
  • Information on sources of your funds.

ROKKEX may also collect some of the Personal Data automatically including:

  • Location information (information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform);
  • Log information (information that is generated by your use of ROKKEX Exchange Services that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time; page response times, download errors, length of visits to certain pages, page interaction informations (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page);
  • Cookies (a browser feature known as “cookie”, which assigns a unique identification to your computer. Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Sites, analyse trends, and administer the Platform. The information collected from cookies allows to determine such things as which parts of the Site are most visited and difficulties the visitors may experience in accessing the Site. This knowledge is used to improve the quality of your experience on the Platform by recognising and delivering more of the most desired features and information, as well as by resolving access difficulties);
  • Account information (information that is generated by your ROKKEX Account activity including, but not limited to, instruction regarding funding and disbursement, orders, trades, and account balances);
  • Correspondence (information that you provide to us in written or oral correspondence, including opening a ROKKEX Account, and with respect to ongoing customer support; and logging of phone numbers used to contact us).

ROKKEX may also receive Personal Data about you from other sources including:

  • The banks you use to transfer money to ROKKEX will provide ROKKEX with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;
  • Business partners may provide ROKKEX with your name and address, as well as financial information;
  • Advertising networks, analytics provider and search information providers may provide ROKKEX with anonymized or de-identified information about you, such as confirming how you found ROKKEX website;
  • Credit reference agencies do not provide us with any Personal Data about you, but may be used to corroborate the information you have provided to ROKKEX.

ROKKEX will process your Personal Data only for the purpose(s) of providing to you the service(s) that you ask ROKKEX to provide you, to satisfy the legal obligations stemming from regulatory obligations that arise from providing you the service(s) and ROKKEX’s legitimate interest.

Based on legal obligations and legitimate interest ROKKEX may request other documents for your identity verification and the sources of your funds confirmation for the purposes of money laundering and fraud prevention. To know more about it please see our AML/KYC and Anti-Fraud policies.

Personal Data you provide during the registration process may be retained, even if your registration is left incomplete or abandoned. If you are located within the EEA, this information will not be retained without your consent.

In providing the Personal Data of any individual (other than yourself) to ROKKEX during your use of the ROKKEX Exchange Services, you promise that you have obtained consent from such individual to disclose his/her personal data to ROKKEX, as well his/her consent to ROKKEX’s collection, use and disclosure of such Personal Data for the purposes set out in this Privacy Policy.

 

CHILDREN’S PERSONAL DATA

ROKKEX Exchange Services are not directed to persons under the age of 18 (the “Minors”) and we do not knowingly collect personal information from Minors. If we learn that we have inadvertently gathered personal information from a Minor, we will take legally permissible measures to remove that information from our records. ROKKEX will require the User to close his/her account and will not allow the use of ROKKEX Services. If you are a parent or guardian of a Minor, and you become aware that a Minors has provided personal information to ROKKEX, please contact us at privacy@rokkex.com and you may request to exercise your applicable access, rectification, cancellation, and/or objection rights.

 

DISCLOSURE OF PERSONAL INFORMATION

ROKKEX may share your personal information with selected third parties including:

  • Affiliates, operational and business partners, suppliers and subcontractors for the performance and execution of any contract ROKKEX enters into with them or you;
  • Analytics and search engine providers that assist us in the improvement and optimization of our site; and
  • Our group entities or subsidiaries.

ROKKEX may disclose your personal information to third parties when ROKKEX:

  • Sells or buys any business or assets, in which case ROKKEX may disclose your personal data to the prospective seller or buyer of such business or assets in order to continue the services for which you have contracted;
  • Is under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply ROKKEX’s Terms & Conditions and other applicable agreements; or to protect the rights, property, or safety of ROKKEX, ROKKEX’s customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
  • Conducts or cooperates in investigations of fraud or other illegal activity whenever ROKKEX believes it is reasonable and appropriate to do so;
  • Seeks to prevent and detect fraud and crime;
  • Receives a lawful subpoena, warrant, court order, or as otherwise required by law;
  • Seeks to protect ROKKEX from financial and insurance risks;
  • Seeks to recover debt or in relation to your insolvency; and
  • Seeks information necessary to maintain or develop customer relationships, services and systems.

ROKKEX does not maintain a published list of all of the third parties with whom it shares your Personal Data with, as this would be heavily dependent on your specific use of ROKKEX Services. However, if you would like further information about who Rokeex has shared your Personal Data with, or to be provided with a list specific to you, you can request this by writing to privacy@rokkex.com.

 

SECURITY. HOW ROKKEX PROTECTS YOUR PERSONAL DATA

ROKKEX has implemented technical and organisational security measures to ensure the confidentiality, integrity and accountability of your Personal Data and to protect your Personal Data from loss, misuse, alteration or destruction.

ROKKEX restricts access of your Personal Data only to those ROKKEX employees, affiliates, and subcontractors who have a legitimate business need for accessing such information. ROKKEX continuously educates and trains its employees about the importance of confidentiality and privacy of customer information. ROKKEX maintains physical, electronic, and procedural safeguards that comply with the relevant laws and regulations to protect your Personal Data from unauthorized access.

In case you have consented to, or ROKKEX is obliged to pass on Personal Data to third parties to provide you with a requested service or in the carrying out of a regulatory or legal obligation, ROKKEX will request that the same levels of technical and organisational security measures be applied through contractual arrangements, where possible.

ROKKEX conducts testing, assessment and evaluation of its technical and organisational measures effectiveness on a regular basis. Technical and organisational security measures in place will, from time to time, be reviewed in line with legal and technical developments.

Despite best practices and technical safeguards, the transmission of information via the internet is not completely secure. Although ROKKEX does its best to protect your Personal Data, the security of your Personal Data during transmission cannot be guaranteed and any acts of transmission are at your own risk.

In the event of a Personal Data breach or the failure of the measures of protection of such information, ROKKEX will immediately notify you without undue delay.

 

RETENTION OF PERSONAL DATA

Your information is held within ROKKEX servers located within the European Union. Access to this information is provided to employees of ROKKEX whose office may also be outside of the European Union but who adhere to the same principles of data security and processes as those within the European Union.

Your payment method information that you may use to effect or receive payments from ROKKEX may be passed on to a third-party payment processor(s) which is/are based in the EU and with which ROKKEX has a contractual agreement to safeguard your rights. Unless you create an account with us and conduct transactions, we do not retain your payment method information.

ROKKEX will hold your Personal Data only for as long as it is necessary for the purposes described in this Privacy Policy and ROKKEX’s legal and regulatory requirements.

In accordance with record keeping activities for Anti-Money Laundering, Tax and Company legal obligations and considering the period during which you may bring legal claims against us under the law of Estonia, ROKKEX will retain Personal Data for a period of six years after the User closes his/her Account and terminates legal relationships with ROKKEX for six years from the end of the tax period in which the User conducts his/her last transaction.

Personal Data stored for regulatory purposes only will be protected from unnecessary processing and will be held only for the purpose of being able to provide information or access to relevant authorities.

By using ROKKEX Services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. In all such transfer, we will protect your Personal Data as described in this Privacy Policy. For more information, please contact us at privacy@rokkex.com.

 

DISPOSAL OF PERSONAL DATA

Once ROKKEX does not have any obligation to providing you with a service you requested, nor an obligation to hold Personal Data for regulatory or legal purpose, your Personal Data will be anonymised or disposed in line with acceptable industry and security standards so that this cannot be subsequently retrieved and associated to you.

Where ROKKEX cannot directly remove such records, such as in archived backups, ROKKEX will retain a log of which Personal Data should be removed if ever the backup data is restored.

 

PROFILING AND AUTOMATED DECISION MAKING

ROKKEX may in some instances use your Personal Data, such as your country of residence and trade history, in order to better address your needs. For example, if you frequently trade in a specific virtual currency, ROKKEX may use this information to inform you of new product updates of features that may be useful for you. By doing this, ROKKEX takes all necessary measures to ensure that your privacy and security are protected, and we only use anonymous or de-identified data.

ROKKEX may use Automated Decision Making (ADM) in order to improve your experience or to help fight financial crime. For example, so that we can provide you with fast and efficient service, we may use ADM to verify your identity documents or to confirm the accuracy of the information you have provided to us. None of our ADM processes has a legal effect on you.

 

MARKETING

ROKKEX will ask you for your consent on registration or post-registration, by providing you with the ability to check marketing preferences checkboxes located within your account profile page to allow ROKKEX to contact you or use your Personal Data for marketing purposes. ROKKEX my also notify its existing Users on its own products or services similar to those ROKKEX have already provided based on its legitimate interest.

You have the right to retract the consent for us to process your Personal Data form marketing purposes. You can exercise your right to prevent such processing by unchecking marketing preferences checkboxes on your account profile or by contacting us at any time on privacy@rokkex.com.

 

YOUR CHOICES

Email Communications – subject to applicable laws and regulations, we may from time to time send communications promoting services, products, facilities or activities to you using information collected from you. When you create a ROKKEX Account you are agreeing to opt-in to all communications from us. We will provide you with an opportunity to opt-out of newsletter communications. We will never provide your Personal Data to third parties for direct marketing or other unrelated purposes without your written consent. Unfortunately, we are unable to allow you to opt-out of the emails we send you for certain legal or administrative purposes.

Cookies – you may decline session cookies if your browser or browser add-on permits but choosing to remove or disable our cookies may interfere with your use and functionality of the ROKKEX Exchange Services.

Right of Rectification – you have the right to correct any personal information we hold on you that is inaccurate, incorrect, or out of date.

Right of Erasure – you have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which ROKKEX is subject to.

Portability – you may have the right to transfer certain of your Personal Data between data controllers, for example, to move your account details from one online platform to another.

Location Information – you may be able to stop the collection of location information through your device settings or by following the standard uninstall process to remove our application from your device; however, because such data is used by us to meet legal requirements, as well as for ongoing fraud and risk monitoring purposes, choosing to remove or disable location services may interfere with your use and functionality of the ROKKEX Exchange Services.

 

ACCESS TO INFORMATION

Subject to applicable laws, you may have the right to access the information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. For further information, please contact privacy@rokkex.com.

 

OUR DATA PROTECTION OFFICER

Our Data Protection Officer is the person in charge of ensuring our company adheres to this Privacy Policy. This person is also the main contact for our Data Protection Supervisory Authority, Estonian Data Protection Inspectorate (www.aki.ee/en). The Data Protection Officer may be contacted on privacy@rokkex.com

 

DATA PROTECTION SUPERVISORY AUTHORITY

Our Data Protection Supervisory Authority in terms of data protection is the Estonian Data Protection Inspectorate www.aki.ee/en. You may contact the authority at info@aki.ee if you wish to discuss with them any instance where you feel we may not be adhering to the terms within this Privacy Policy or to raise a complaint.

 

CHANGES TO THIS PRIVACY POLICY

Our policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of ROKKEX.

Any changes we make to our Privacy Policy will be posted on this page and, where appropriate, notified to you by privacy@rokkex.com. Please check back frequently to see any updates or changes to our Privacy Policy.

If we consider that your rights may be affected by any such changes, we will request you to confirm your consideration and acceptance prior to continuing our relationship with you.

 

FRAUD, PHISHING AND EMAIL SCAMS DISCLAIMER

Please be notified that ROKKEX is not in any partnership with entities who represent themselves as customer support agents, providing customer support services via phone and/or social media and promise to help solve your issues for money. Remember – customer support is provided only by the ROKKEX website and is always provided free of charge.

If you discovered what you believe is a fraud, phishing or scam which impersonate ROKKEX, please contact us at privacy@rokkex.com.

 

CONTACT US

Any questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to privacy@rokkex.com.