When you visit Bitenny’s websites or use our (future) app ("we" or "us"), correspond with Bitenny or become (or are in the process of becoming) one of our (prospective) users, (prospective) merchants or (future) partners, Bitenny processes personal data about you as a data controller. It is important to Bitenny that the personal data of the users of the (future) app, the visitors to our websites, our (prospective) merchants and our (future) partners ("you") are treated with care and that you are well informed about the way Bitenny processes your personal data. 
Personal data Bitenny collects and why
 
When you browse our website our (future) app, we process your IP address, Google Analytics ID, internet browser and device type, location data and your use of the (future) app and our website, including which pages you visited, how you got to our website, the time and length of your visit and your language preferences. Bitenny uses this data for our legitimate interests of making sure our website works properly, including debugging, to be able to deliver you content and for DDOS mitigation on our website, and improving our website and to perform statistical analyses for optimizing our website. Further, Bitenny uses this information to provide you with personal offers tailored to your needs and tailoring what Bitenny shows you to your preferences, with your prior consent.
Bitenny collects this data using cookies and similar techniques, including tags/beacons and javascripts. More information about these techniques can be found in our Cookies Policy.
When Bitenny collects information about how you use our website or our (future) app, for example which landing pages you visit and which items you look at and how long, to make a determination about what Bitenny could likely do for you. For example, if you read about our products and services on our website, Bitenny might classify you as user or a website visitor who is interested in our products and services and therefore as a potential merchant. Based on the audience Bitenny expects you belong to, we may act, for example by contacting you with offers about our products and services, if we have your consent for this.
In order to make the most accurate assessment about which audience you likely belong to, and as you can also read in our Cookies Policy, Bitenny also uses tracking cookies. These cookies track information about how you use our website and which other websites you visit, for example to show you advertisements if our products and services we suspect you might be interested in. Bitenny only places these tracking/targeting cookies with your prior consent. 
Data we collect when you contact us or request us to contact you
Via our website, you can contact us or ask us to contact you regarding queries, (support) requests, comments or complaints, fill out an application to become an user, a merchant or a partner or sign up for a test account. When you do this,  Bitenny collects the information that you fill out, including but not limited to your (company)name, e-mail address, phone number, other contact details, the reason you are contacting us, verification that you are not a robot and other information you decide to provide us. You can also contact us by calling us or e-mailing us using for example the contact details listed on our website. If you do so, Bitenny will collect your (company)name, and any other information required to be of further assistance to you and/or communicate with you.
Bitenny uses this data to answer your queries, comments or complaints and respond to your queries and (support) requests and to assess your application to become an user,  merchant or partner. As such, this data is used by Bitenny to establish or perform our (future) contract with you and for our legitimate interests in following up with you. Bitenny also uses the data for our legitimate interest of conducting business with you and managing our internal administration, for establishing and performing our contract with you, for our legitimate interest of conducting marketing research so Bitenny can improves its products and services and to offer tailored products and services.
Data Bitenny process for marketing purposes
You can sign up for our newsletter or receive invitations to events using your name and e-mail address via the sign-up form on our website or the (future) app. When you fill out this form, you indicate your consent to receive our newsletter and invitations. You can at any time unsubscribe from receiving these e-mails by following the instructions provided in any of the newsletters.
You can also download content, for example white papers from our website using the forms designed for this purpose. Bitenny collects the data you fill out on the forms, including your name, (company)name, country and e-mail address. Bitenny processes the data you fill out on this forms for our legitimate interest of keeping track of who downloads our content.
Data Bitenny processes when you sign up 
If you sign up to become one of our users or merchants, Bitenny collects information it needs to establish and perform a contract with you, including but not limited to your contact information, address and, order details, tax information and payment details. Bitenny uses this information to set up our products and services for you, including to provide you with support, boarding, integration, installation, helping you with settings and all other actions which need to be taken to establish or perform our contract with you. Further, Bitenny uses your information for our legitimate interest of managing our internal administration and for complying with our legal obligations.
Bitenny also collects data about your use of our products and services and your account, including your login details, and the queries, comments and complaints you send us in relation to our business relationship. Bitenny processes this data to be able to perform its contract with you by following up with you and providing you with support and for its legitimate interest of being able to optimize and improve its products and services.
Bitenny also uses your contact details for keeping you up to date on our products and services and to make you offers tailored to your needs (meaning of similar products and services you have already purchased from us).
Bitenny has an obligation to act in compliance with all relevant laws, regulations and sanctions and to prevent laundering proceeds of crime or financing terrorism. As Bitenny is active in the financial industry, Bitenny is not allowed to accept just any user, merchant or partner without checking them and we have to determine and report when suspicious transactions take place. Therefore, if you are applying to become one of our, users, merchants or partners, Bitenny will often need to collect information and documents to:

·         verify your identity;
·         identify the ultimate beneficial owners of your business;
·         identify the purpose and intended nature of your future business relationship with us;
·         monitor your transactions using automated systems which detect risks and verify the origins of your capital/assets; 
·         check whether a natural person representing you is competent to do so (and verify the identity of this person); and
·         check whether you act on behalf of yourself or on behalf of a third party.
To carry out the above checks, Bitenny processes a copy of your identification document, the address of your legal representative and shareholders, your bank account number, your contact information, information contained in correspondence between us, bank statements, your signature, an extract of your company registration document and all other information required. Bitenny uses this data to ensure the safety and integrity of the financial sector by aiming to identify, prevent and counter illegal conduct and to comply with our legal know-your-customer and anti-money laundering obligations, under all relevant laws (including but not limited to the Dutch Financial Supervision Act (Wft) and the Dutch Money Laundering and Terrorist Financing Prevention Act (Wwft).
Other Purposes
If required, Bitenny also processes any of your information for our legitimate interest of protecting our legal rights, for example in connection with legal claims, and when we have a legal obligation to process your information. Bitenny may also transfer your data in the event of a company reorganization, acquisition, merger, or sale.
Data retention 
Our retention periods for personal data are based on business needs and legal requirements. Bitenny retains personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, Bitenny may retain the information you provided to us as long as necessary to provide you with the services you requested through our website or (future) app and until the time limit for claims which may arise from those services has expired, or to comply with regulatory requirements regarding the retention of such data. So if Bitenny uses your personal information for more than one purpose Bitenny will retain it until the purpose with the latest period expires but we will stop using it for the purpose(s) with a shorter period once that period expires.
When personal data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data. 
Social media buttons
Bitenny uses plugins on our website from social media networks such as Facebook, Instagram, LinkedIn and Twitter. You can recognize these plugins by their logos. Bitenny also uses plugins for the embedded video players which can be found on our website. Our plugins will not collect personal data about you, unless you click on these logos or videos. If you click on them, these plugins are activated and automatically transmit data to the plugin provider.
Bitenny does not have any influence over which data these providers collect from you and we are also not aware of the extent of their data processing. If you would like more information about their data processing, this can be found in the respective privacy policies on the websites of these providers.
Cookies
Bitenny uses cookies and similar techniques, such as tags/beacons and javascripts, which are small text files stored on your device. Using cookies is a way for Bitenny to make sure that our website is continuously improved, meets your needs and can be used as a tool to optimize our marketing strategy. In order for Bitenny to do this, Bitenny places functional cookies to make the website function as well as marketing cookies which help us target the right people and show them advertisements. Some of these cookies track your use of our website and visits to other websites and allow us to show you advertisements when you browse other websites.
Please refer to our Cookies Policy for further information.  

Transmission and security of your personal information
 
Bitenny needs help of third parties to be able to offer you our website and our products and services. Where necessary Bitenny will share your information with our service providers and professional advisers. Bitenny has concluded agreements with our service providers to protect your personal data.
Otherwise Bitenny will not share your information with any third party, unless we have your consent, where this is necessary in connection with the purposes above or with legal claims or when we have a legal obligation to do so.
Bitenny is committed to secure your personal data. In order to prevent unauthorized people or parties from being able to access your data, Bitenny has put in place a range of technical and organizational measures to safeguard and secure the information we process from you.
Some of the information you send us may be shared with other (future) group companies outside of the European Economic Area ("EEA"), when this is necessary for the purposes mentioned above. These countries include the countries in which Bitenny will have future operations. It also includes the countries in which some of our service providers are located, such as the United States.
Where we transfer personal information from inside the EEA to outside the EEA, we may be required to take specific additional measures to safeguard the relevant personal information.  
Your Rights 
You are entitled to object to us processing your personal data, including profiling. You may also ask us for an overview of your information or ask for a copy. You may also request us to correct or delete certain data, restrict processing of your data, or ask us to transfer some of this information to other organisations. In some cases you may object to the processing of your data and, where Bitenny has asked for your consent to process personal data, you can withdraw this consent at any time. Where Bitenny processes your data for our legitimate interests, you can contact us if you want more information about these.
There are some exceptions to these rights. For example, it will not be possible for us to delete your data if Bitenny is required by law to keep it or if we hold it in connection with a contract with you. Access to your data may be refused, if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information.
Changes
Bitenny may change the content of its websites or apps and how we use cookies and consequently, our privacy policy and our Cookies Policy may change from time to time in the future.  
 
Contact
Queries or complaints concerning this privacy notice could be addressed to info@bitenny.io