ONIT Privacy Policy

Last updated: November 17th, 2016

This Privacy Policy explains how ONIT, LLC, and its wholly owned subsidiaries (collectively, ONIT, we or us), collects, uses, discloses and protects your information. This policy applies to information we collect when you access or use ONIT\s websites and mobile applications (collectively, ONIT Services) or otherwise interact with us as described below. ONIT provides the ONIT Services through local operating entities that are wholly owned subsidiaries of ONIT, LLC (each, a ONIT Company). To determine which ONIT Company collects your information and is responsible for processing your data, please refer to our list of affiliated companies: /en/articles/about_us.

We may amend this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some circumstances, we may provide you with additional notice, including, for example, by adding a statement to the homepage of the ONIT Services or by sending you an email notification. We strongly encourage you to review the Privacy Policy whenever you access or use ONIT Services to stay informed about our information practices and your privacy rights and choices.

COLLECTION OF INFORMATION

Information You Provide To Us

We collect information you provide directly to us. For example, we collect information about you when you create an online account, complete a transaction, fill out a form, respond to surveys, post messages to our forums or wikis or otherwise communicate with us.

The types of information we may collect are as follows:

• Contact information, such as your name, mailing address, telephone number, and email address.
• Financial information, such as bank account numbers, credit card numbers and virtual currency account information.
• Government identification numbers, such as your social security number or a state-issued identification number.
• 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 We Collect From Other Sources

We may also obtain information from other sources and combine that with information we collect through the ONIT Services. For example, we may collect nonpublic personal information about you from third parties, including identity verification services.

Information We Collect Automatically

When you access or use the ONIT Services, we automatically collect information as follows:

• Transaction information: we collect information about the transaction you complete via the ONIT Services, including the amount of funds associated with a trade, the types of trades executed and other transaction information.
• Location information: with your prior consent, we may collect precise geolocation information from your mobile device when you access or use our mobile applications. For more details, please see Your Choices below.
• Device and Log information: we collect information about the computer or mobile device you use to access the ONIT Services, including device identifiers, mobile network information, type of operating system, and the type of browser used. We also log information about your use of the ONIT Services, including access times, pages viewed, IP address, other standard web log data, and the page visited before and after navigating to our websites.
• Cookies and similar tracking technologies: we may use cookies, pixel tags, web beacons, and other tracking technologies to collect information about you when you interact with the ONIT Services, including information about your browsing behaviour on our ONIT Services. Cookies are small data files sent from our web servers to your computer or mobile device that enable us to, for example, capture how you arrived at the ONIT Services, when you return, which pages on the ONIT Services you visit, and to recognise that you are already logged on when we receive a page request from your browser.

USE OF INFORMATION

We may use your information as follows:

• Provide the ONIT Services and customer support;
• Process transactions and send notices about your transactions;
• Manage your account(s) and send technical notices, updates, security alerts and support and administrative messages;
• Resolve disputes, collect fees, and troubleshoot problems;
• Prevent potentially prohibited or illegal activities and enforce our user agreements;
• Personalize, measure and improve the ONIT Services;
• Deliver marketing and promotional offers on behalf of ONIT and others, including via SMS, voice calls or email;
• Link or combine your personal information with information we obtain from others to help understand your needs and provide you with better service; and
• Carry out any other purpose for which the information was collected, to the extent such purpose is necessarily contemplated by the collection of such information or as otherwise notified in the ONIT Services at the time of collection.

PROCESSING OF INFORMATION

The ONIT Company in the U.S. (ONIT Ventures, LLC) processes data on behalf of all ONIT Companies. If you are located in any jurisdiction other than the U.S., your data will be transferred to ONIT Ventures, LLC for processing as directed by ONIT Company responsible for your data processing. If the ONIT Company responsible for processing your data is ONIT Ventures, LLC, then your information will be processed solely by that U.S. entity and your information will not be transferred to any other ONIT Company.

By accessing or using the ONIT Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries. Please refer to the U.S. – EU / Swiss Safe Harbor Compliance section below if you are a resident of the European Union or Switzerland.

DISCLOSURE OF INFORMATION

We may disclose any information we collect about you, whether you are a current or former customer, including nonpublic personal information and any other information we collect, to ONIT Ventures, LLC in the U.S., which processes information on behalf of all ONIT Companies, and with nonaffiliated third parties, which include non-financial companies, such as email service providers and fraud verification services, and others, such as other ONIT users with which you engage in transactions. We may make such disclosures:

(1) To service providers that perform marketing services on our behalf; and

(2) For our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share information about you as follows:

• With any party you intend to distribute funds to, or that intends to distribute funds to you, via the ONIT Services, including information about whether your account is active and whether the account has been verified.
• With vendors, consultants and other service providers who need access to your information to carry out work on our behalf. These service providers help with our business operations such as fraud prevention and technology services.
• When we believe, in our sole discretion, that the disclosure of your information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of or enforce our user agreements or other policies and agreements.
• In connection with, or during negotiations of, any merger, sale of ONIT’s assets, financing or acquisition or all or a portion of our business to another company.
• With your consent or at your direction.

(3) If we are under a duty to disclose or share your information to comply with our legal obligations.

Other than in connection with a merger, sale of ONITs assets, financing or acquisition, we will not sell or rent any of your information to third parties for their own marketing purposes.

Please note that third parties that support our customer identification and anti-fraud controls may retain and use information about you to perform services on our behalf and to improve their services. By using our Services, you consent to the retention and use of such information by these providers to improve their services.

We may also share aggregated or de-identified information with our affiliated companies or nonaffiliated third parties, which cannot reasonably be used to identify you.

ANALYTICS SERVICES PROVIDED BY OTHERS

We allow other entities to provide analytics services on our behalf. These entities may use cookies, web beacons and other tracking technologies to collect information about your use of the ONIT Services, including your IP address, web browser, pages viewed, time spent on pages and links clicked. This information may be used by ONIT to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

SECURITY

We implement reasonable security practices and procedures to help protect the confidentiality and security of your information, including any nonpublic personal information. We protect your information using reasonable physical, technical and administrative security measures, including by limiting access to your information to employees with a need to know such information.

U.S. – EU / SWISS SAFE HARBOR COMPLIANCE

ONIT complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. ONIT has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view ONIT’s certification, please visit http://www.export.gov/safeharbor/

If you have a complaint regarding ONIT’s compliance with the U.S.-EU Safe Harbor Framework or the U.S.-Swiss Safe Harbor Framework, first contact us through support at [email protected]. ONIT has elected to use JAMS arbitration as an independent recourse mechanism available to settle unresolved complaints regarding ONIT’s Safe Harbor commitments. Please refer to the section titled “Applicable Law; Arbitration” in our Terms of Service /en/articles/legal_privacy

YOUR CHOICES

• Account Information: You may access and review or update your online account information at any time by logging into your account and viewing your profile. If you want to close your account, please contact us at [email protected]. However, please note that if you close your account, we may retain your information as required by law or for our legitimate business purposes, such as to collect fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud or enforce our user agreements.
• Communications Preferences: You may opt out of receiving promotional communications from ONIT by following the instructions in those communications. You may also opt out of receiving the n.exchange newsletter or certain administrative emails by modifying your communications preferences through the settings feature of your online account. If you opt out of receiving promotional communications, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.
• Location: Our mobile applications may collect precise geolocation information from your mobile device with your prior consent. If you initially consent to our collection of location information, you may be able to subsequently stop the collection of this information through your device operating system settings. You may also stop our collection of location information by following the standard uninstall process to remove our mobile applications from your device.
• Cookies: We use both session and persistent cookies. Session cookies expire when you log out of your account or close your browser. Persistent cookies remain on your computer or mobile device until you erase them or they otherwise expire. Most web browsers are set to accept cookies by default. You are free to decline most of our 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 ONIT Services. Additionally, we may use certain persistent cookies that are not affected by your browser settings, but will use such cookies solely for identity verification and fraud prevention purposes. For more information about cookies and how to block, delete or disable them, please refer to your browser instructions, or contact us at [email protected].
• Why cant I opt out of any sharing? We do not engage in any sharing that would require us to provide you with an ability to opt out of such sharing. For instance, we do not share any information about you with third parties for their own marketing purposes.

ACCESS TO INFORMATION

You have a right to access the information we hold about you. We may ask you to pay a fee before providing you with this information.

CONTACT US

If you have any questions or concerns regarding this Privacy Policy, please contact us at [email protected].