PRIVACY AND PERSONAL DATA PROTECTION POLICY (“PRIVACY POLICY”)

1. Maxonrow Ltd. (“Maxonrow”) collects your personal information when you register with us to use our platform (“Platform”), use Maxonrow websites, mobile applications or other services (“Services”) or otherwise contact us online. We use this personal information to: provide you Services you have requested; create your Maxonrow Account (“Account”); to send you information about the Services and your registration; to send you marketing information; and to respond to your correspondence. By using these Services, you agree to the terms of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services. We reserve the right to make changes in this Privacy Policy, so please check back from time to time to ensure you are aware of any changes. Your continued use of the Services will signify your acceptance of these changes.

2. This Privacy Policy describes the treatment of information provided or collected on the websites where this Privacy Policy is posted. It also explains the treatment of information provided or collected on applications we make available on third-party websites or platforms if disclosed to you in connection with use of the application. We follow this Privacy Policy in accordance with local law in the places where we operate.

3.This Privacy Policy applies only to the Services on which this Privacy Policy is made available by Maxonrow and not to websites, networks or platforms maintained by other companies or organizations to which we may provide links. Please note, however, that when you link to any other third-party websites from our Services, this Privacy Policy no longer applies. Maxonrow does not control the activities on those third-party services and cannot and does not guarantee the security of any personal information disclosed on those third-party services.

4. WHEN DOES COLLECTION TAKE PLACE

A. Maxonrow collects your personal information at different times when you make use of our Services. Generally, personal information is collected when:

  • you use our Services;
  • you create an Account;
  • you watch advertisements within our Services;
  • you sign up to a newsletter;
  • you contact Maxonrow customer service and during technical support sessions;
  • you enter into Maxonrow contest or promotion;
  • you chat with other users of the Services via the Platform or Maxonrow’s websites or mobile applications;
  • you wish to participate in a beta or otherwise use trial version of the Platform; or you share or otherwise contribute to our social media channels and other community websites.

B. Whatever the activity may be, we will only collect personal information to the extent deemed reasonably necessary to fulfil your requests and our legitimate business objectives.

C. If you do not submit personal information when asked by Maxonrow, your refusal may limit our ability to process your Account creation, provision of Services, contest or promotion registration, or request for technical support.

D. Since the basis of processing your data is the consent you grant, we hereby inform you that consent may be withdrawn at any time. Please be advised that revoking your consent will require the closing of your Account at Maxonrow and the revocation will only take effect in the future. Any processing that was carried out prior to the revocation shall not be affected thereby.

5. TYPES OF INFORMATION COLLECTED

A. We collect the following categories of information:

  • Registration information you provide when you create an Account, including your first name and surname, country of residence, gender, date of birth, email address, username and password;
  • Transaction information you provide when you request information or use our Services, whether on our websites or through our applications, including your postal address, telephone number, payment information and cryptocurrency wallet address;
  • Information you provide in public forums on our Platform, websites and applications;
  • Information sent either one-to-one or within a limited group using our message, chat, post or similar functionality, where we are permitted by law to collect this information;
  • Location information when you visit our websites or use our applications, including location information either provided by a mobile device interacting with one of our websites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information; and
  • Usage, viewing and technical data, including your device identifier or IP address, when you visit our websites, use our applications on third-party websites or platforms or open emails we send.

6. HOW YOUR INFORMATION IS COLLECTED

  • We collect information you provide to us when you use our Services or request information from us, register with us, participate in public forums or other activities on our websites and applications, respond to customer surveys, or otherwise interact with us using one or more devices. Please keep in mind that when you provide information to us on a third-party website or platform, the information you provide may be separately collected by the third-party website or platform. The information we collect is covered by this Privacy Policy and the information the third-party website or platform collects is subject to the third-party website or platform’s privacy practices. Privacy choices you have made on the third-party website or platform will not apply to our use of the information we have collected directly through our applications.
  • We collect information through technology, such as cookies, Flash cookies and Web beacons, including when you visit our websites and applications or use our applications on third-party websites or platforms using one or more devices. Please see our Cookie Policy appended herewith as Appendix 1 for more information.
  • We acquire information from other sources to update or supplement the information you provided or we collected automatically. Local law may require that you authorize the third party to share your information with us before we can acquire it.

7. USE OF YOUR INFORMATION BY MAXONROW

The data controller and data user of the data collected in respect to this Privacy Policy is Maxonrow. Third parties may have access to your information where they perform services on behalf of the data controller(s) (as a data processor) and, unless prohibited under applicable law, for use on their own behalf (as a data controller) for the following purposes:

Facilitate the use of any Services; Communicate with you about your Account or transactions with us and send you information about features on our websites and applications or changes to our policies; Consistent with local law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:

Send you offers and promotions for our Services or third-party products and services; Personalise content and experiences; Provide you with advertising based on your activity on our websites and applications and on third-party websites and applications; Optimise or improve our Services and operations; and detect, investigate and prevent activities that may violate our policies or be illegal.

8. SHARING YOUR INFORMATION WITH OTHER PARTIES

We will not share your personal information with other parties aside from Maxonrow’s agents and affiliates, except in limited circumstances, including when you allow us to share your personal information with another company, such as:

Electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services; Directing us to share your personal information with third-party websites or platforms, such as social networking websites; When companies perform services on our behalf, such as customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law; and When we share personal information with third parties in connection with the sale of a business, to enforce our terms and conditions or policies, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process or in other cases if we believe in good faith that disclosure is required by law, including, for the avoidance of doubt, when lawfully required to disclose to the relevant government or authorities. Please note that once we share your personal information with another company, the information received by the other company becomes subject to the other company’s privacy practices.

9. YOUR CONTROLS AND CHOICES

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with local law, your controls and choices include the right to correct, update and delete your Account.

You may exercise your controls and choices, or request access to your personal information, including if for any reason you wish to question, view, correct or delete the personal information collected about you by Maxonrow or its technical partners, by filling out a Personal Information Correction/Update Form in the English language and sending it to the Maxonrow Support Centre, or following instructions provided in communications sent to you. The Personal Information Correction/Update Form can be found appended to this Privacy Policy as Appendix 2. We will be happy to review, update or remove information as appropriate. However, we may still retain information in our files to resolve disputes, enforce our agreements, due to technical or legal requirements or matters related to security, integrity or operation of our Services.

This Privacy Policy has incorporated elements from the General Data Protection Regulation as we act in accordance to its personal information processing rules within European Economic Area. If you are located in or are a citizen of the European Union, you may have the following rights with some exceptions in relation to personal information that we hold about you:

To request confirmation of whether we process personal information relating to you, and if so, to request a copy of that personal information; to request that we rectify or update your personal information that is inaccurate, incomplete or outdated; to request that we erase your personal information in certain circumstances, such as where we collected personal data on the basis of your consent, and you withdraw your consent; to request that we restrict the use of your personal information in certain circumstances; where you have given us consent to process your personal information, to withdraw your consent; and to request that we provide a copy of your personal information to you in a structured, commonly used and machine-readable format in certain circumstances.

10. DATA SECURITY, INTEGRITY AND RETENTION

The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

11. DATA TRANSFERS, STORAGE AND PROCESSING GLOBALLY

We operate globally and may transfer your personal information to our related bodies corporate or third parties in locations around the world for the purposes described in this Privacy Policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information from unlawful access.

12. CONTACT

If you have any questions or complaints or comments about this Privacy Policy or our use of your personal information, please contact Maxonrow Support Centre.

13. CHANGES TO THIS PRIVACY POLICY

From time to time, we may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. You are deemed to agree and consent to any changes in this Privacy Policy by way of your continued use of our Services.

14. PRIVACY POLICY AND TERMS AND CONDITIONS

The terms of this Privacy Policy are incorporated into our Terms of Use.

 

APPENDIX 1

COOKIE POLICY

  1. Maxonrow may collect your personal information provided to or collected by Maxonrow via cookies and other tracking technologies. By using our websites, you are deemed to agree and consent to our use of cookies in accordance with this Cookie Policy and our Privacy Policy.
  2. Cookies are used to help speed up your future activities and your experience on Maxonrow We use cookies to make Maxonrow websites easier to use, to recognise when you log in and any preferred settings, to deliver a personalised experience on our websites, to better tailor our services and websites to your interests and needs, and to analyse how you use our website which helps us troubleshoot any problems and to monitor our own performance.
  3. To opt out of these cookies you will need to change the settings on your browser Cookie preferences. If you choose to block these cookies our website may not work as it should and any preferences you have may be lost. Please take note that Maxonrow is not responsible for any loss resulting from your decision or inability to use cookies.
  4. We may update this Cookie Policy from time to time. You are deemed to agree and consent to any changes in this Cookie Policy by way of your continued use of our Services, as defined in the Privacy Policy.

 

APPENDIX 2

PERSONAL INFORMATION CORRECTION/UPDATE FORM

Name: Date:
Passport No (optional for customers):  
Contact Details (address/phone/email):  

 

Previous Data New Data to be Updated

 

 

 

 

 
  1. Please ensure accuracy when providing us with the information requested in this form. The personal information submitted by you to us in this form is necessary for processing your request and any inaccuracies, errors or omissions in the personal information submitted may result in delays in processing the request and/or our inability to process your request.
  2. Your correction request will be subject to approval following our receipt and approval of this completed form.
  3.  We reserve the right to refuse to process the Personal Information Correction/Update Form in accordance with the provisions of local law.
  4. We may have disclosed the personal information to be corrected herein to third parties in accordance with our Privacy Policy and we may disseminate your corrections herein to those third parties. If you wish to restrict the third parties to which we may make such disclosures, please identify the third parties to whom we may share these corrections.
  5. Words with a capital letter used in this update form shall have the meanings ascribed to them under our Privacy Policy unless the context otherwise admits.

Confirmation

I confirm that this personal information correction request relates to my own personal information or relates to the personal information of a third party whose consent I have obtained. I declare that the personal information provided in and with this request is true in every respect, and I agree that such personal information may be collected, used and disclosed by Maxonrow and its authorised third parties for the purpose of processing this request and/or in accordance with its Privacy Policy.

Signature:

 For internal use:
Received by:  Date:
Processed by: Date: