Privacy Policy

Updated: [*]
BITCI GLOBAL (“BITCI”, “we”, “us”, or “our”) is committed to protecting your privacy.
We have prepared this Privacy Policy to describe to you our practices regarding the Personal
Data (as defined below) we collect, use, and share in connection with the “”
website, mobile app, and other software provided on or in connection with our services
(“Platform”), as described in our User Agreement (collectively, the “Service”).
By accepting the Open Consent Declaration and to visit Platforms, to download contents from
Platforms and/ or to use them and to use other online services reveals that you have accepted
this Privacy Policy.  If you do not accept this Privacy Policy, please do not visit our
Platforms and/or do not use our online services.
The expression; “processed” or “to process” specified in this Policy; means all kinds of
actions made on your personal data such as; to obtain your personal data either through
automatically- partially or completely, or non-automatically, provided to be a part of a data
recording system, to record, store, maintain, preserve, change, re-regulate, explain, transfer,
take over, to make them obtainable, to classify or to obstruct its use.
This Privacy Policy; as we have no controlling effect over them, is not valid in other third-
party web sites which you reach through web connections in Platforms, in applications and
other media and programs.  Besides, this Privacy Policy may be changed through platforms
from time to time.  We suggest you to check this document periodically to get aware of the
changes. Platforms shall always publish the recent version of this Privacy Policy.
1. Collection of Data
By accepting our Open Consent Declaration in order to  use any service or content through
Platforms, you hereby give your explicit consent in accordance with this Privacy Policy and
relevant legislation for the processing of your personal data which are shared with  BITCI;
while using  (i) the information shared with us while using Platforms  and (ii)  the services
included  in platforms, collects the information, which are obtained automatically according
to the purposes specified in this Policy, to the extent permitted by the law .
2. Information That We Collect and the Purpose of Collection
In order to protect your privacy rights, we process your personal data in accordance with the
relevant legislation BITCI; as given in Privacy Notice in detailed manner below, we use your
personal data in order to render you quality and productive service, to develop our services, to
maximize the customer satisfaction.
Within the scope of liabilities imposed by legal and regulatory authorities, we can process
your personal data and share them which included in the Information Category collected
below in order to comply with the liabilities which are brought for third parties such as court,
administrative or judicial authorities in connection with investigations or prosecutions made
in the country or abroad, or for those which are imposed by legal and regulatory authorities.
To the extent permitted by relevant authorities and unless affecting the avoidance of

a commitment or determination of an offense, we will do our best to direct such requests to
you or to make you informed prior to replying them.
Besides, we may use your personal data to adapt our products and services so as to be capable
of meeting your needs and to create internal statistics for marketing, consumer profiles or
demographic surveys. We hereby aim to understand our users better and to render better
service to them.

I. Types of Data We Collect & Data Categories
“Personal Data” means data that allows someone to identify you individually, including, for
example, your name, email address, as well as any other non-public information about you
that is associated with or linked to any of the foregoing such as;
 Identity
 Communication
 Finance
 Transaction Security Information
 Customer Transaction Information
 Professional Experience
 Marketing
 Legal Action Information
 Audio and Visual Recordings
“Anonymous Data” means data, including aggregated and de-identified data, that is not
associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit
the identification of individual persons. We collect Personal Data and Anonymous Data as
described below.
a. Information You Provide Us
 When you use our Service, update your account profile, or contact us, we may collect
Personal Data from you, such as email address, first and last name, user name, and
other information you provide. We also collect your crypto asset wallet address, which
may become associated with Personal Data when you use our Service.
 Our Service lets you store preferences like how your content is displayed, notification
settings, and favorites. We may associate these choices with your ID, browser, or
mobile device.
 If you provide us with feedback or contact us, we will collect your name and contact
information, as well as any other content included in the message.
 We may also collect Personal Data at other points in our Service where you
voluntarily provide it or where we state that Personal Data is being collected.
b. Information Collected via Technology.
As you navigate through and interact with our Service, we may use automatic data collection
technologies to collect certain information about your equipment, browsing actions, and
patterns, including:

 Information Collected by Our Servers. To provide our Service and make it more
useful to you, we (or a third-party service provider) may collect information from you,
including, but not limited to, your browser type, operating system, Internet Protocol
(“IP”) address, mobile device ID, blockchain address, wallet type, and date/time
 Log Files. As is true of most websites and applications, we may gather certain
information automatically and store it in log files. This information may include IP
addresses, browser type, Internet service provider (“ISP”), referring/exit pages,
operating system, date/time stamps, and clickstream data. We may use this
information to analyze trends, administer the Service, track users’ movements around
the Service, and better tailor our Services to our users’ needs. For example, some of
the information may be collected so that when you visit the Service, it will recognize
you and the information can be used to personalize your experience.
 Cookies. Like many online services, we use cookies to collect information. We may
use both session Cookies (which expire once you close your web browser) and
persistent Cookies (which stay on your computer until you delete them) to analyze
how users interact with our Service, make improvements to our product quality, and
provide users with a more personalized experience.
 Pixel Tag. In addition, we may use “Pixel Tags” (also referred to as clear Gifs, Web
beacons, or Web bugs). Pixel Tags allow us to analyze how users find our Service,
make the Service more useful to you, and tailor your experience with us to meet your
particular interests and needs.
 How We Respond to Do Not Track Signals. Our systems do not currently recognize
“do not track” signals or other mechanisms that might enable Users to opt out of
tracking on our site.
 Analytics Services. In addition to the tracking technologies, we place like Cookies
and Pixel Tags, other companies may set their own cookies or similar tools when you
visit our Service. This includes third-party analytics services (“Analytics Services”)
that we engage to help analyze how users use the Service. The information generated
by the Cookies or other technologies about your use of our Service (the “Analytics
Information”) is transmitted to the Analytics Services. The Analytics Services use
Analytics Information to compile reports on user activity, which we may receive on an
individual or aggregate basis. We use the information we get from Analytics Services
to improve our Service. The Analytics Services may also transfer information to third
parties where required to do so by law, or where such third parties process Analytics
Information on their behalf. Each Analytics Services’ ability to use and share
Analytics Information is restricted by such Analytics Services’ terms of use and
privacy policy. By using our Service, you consent to the processing of data about you
by Analytics Services in the manner and for the purposes set out above.
c. Information Collected from Third-Party Companies
We may receive Personal and/or Anonymous Data about you from companies that offer their
products and/or services for use in conjunction with our Service or whose products and/or
services may be linked from our Service. For example, third-party wallet providers provide us
with your wallet address and certain other information you choose to share with those wallets’
providers. We may add this to the data we have already collected from or about you through
our Service.
d. Public Information Observed from Blockchains

We may collect data from activity that is publicly visible and/or accessible on blockchains.
This may include blockchain addresses and information regarding purchases, sales, or
transfers of cryptocurrencies, which may then be associated with other data you have
provided to us.
II. Use of Your Personal Data
a. We may process your Personal Data to run our business, provide the Service, personalize
your experience on the Service, and improve the Service. Specifically, we use your Personal
Data to:
 facilitate the creation of and secure your account;
 identify you as a user in our system;
 improve the administration of our Service and quality of experience when you interact
with our Service, including, but not limited to, by analyzing how you and other users
find and interact with the Service;
 provide customer support and respond to your requests and inquiries;
 investigate and address conduct that may violate our User Agreement;
 detect, prevent, and address fraud, violations of our terms or policies, and/or other
harmful or unlawful activity;
 send you a welcome email to verify ownership of the email address provided when
your account was created;
 send you administrative notifications, such as security, support, and maintenance
 send you newsletters, promotional materials, and other notices related to our Services
or third parties' goods and services;
 respond to your inquiries related to employment opportunities or other requests;
 comply with applicable laws, cooperate with investigations by law enforcement or
other authorities of suspected violations of law, and/or to pursue or defend against
legal threats and/or claims; and
 act in any other way we may describe when you provide the Personal Data.
b. We may create Anonymous Data records from Personal Data. We use this Anonymous
Data to analyze request and usage patterns so that we may improve our Services and enhance
Service navigation. We reserve the right to use Anonymous Data for any purpose and to
disclose Anonymous Data to third parties without restriction.
III. Disclosure of Your Personal Data
We may disclose your Personal Data as described below and as described elsewhere in this
Privacy Policy.
 Third Party Service Providers. We may share your Personal Data with third party
service providers to: provide technical infrastructure services; conduct quality
assurance testing; analyze how our Service is used; prevent, detect, and respond to
unauthorized activities; provide technical and customer support; and/or to provide
other support to us and to the Service.

 Affiliates. We may share some or all of your Personal Data with any subsidiaries,
joint ventures, or other companies under our common control (“Affiliates”), in which
case we will require our Affiliates to honor this Privacy Policy.
 Corporate Restructuring. We may share some or all of your Personal Data in
connection with or during negotiation of any merger, financing, acquisition, or
dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure
of all or a portion of our business or assets. In the event of an insolvency, bankruptcy,
or receivership, Personal Data may also be transferred as a business asset. If another
company acquires our company, business, or assets, that company will possess the
Personal Data collected by us and will assume the rights and obligations regarding
your Personal Data as described in this Privacy Policy.
 Legal Rights. Regardless of any choices you make regarding your Personal Data (as
described below), BITCI may disclose Personal Data if it believes in good faith that
such disclosure is necessary: (a) in connection with any legal investigation; (b) to
comply with relevant laws or to respond to subpoenas, warrants, or other legal process
served on BITCI; (c) to protect or defend the rights or property of BITCI or users of
the Service; and/or (d) to investigate or assist in preventing any violation or potential
violation of the law, this Privacy Policy, or our User Agreement.
 Other Disclosures. We may also disclose your Personal Data: to fulfill the purpose
for which you provide it; for any other purpose disclosed by us when you provide it;
or with your consent.
IV. Third-Party Websites.
Our Service may contain links to third-party websites. When you click on a link to any other
website or location, you will leave our Service and go to another site, and another entity may
collect Personal Data from you. We have no control over, do not review, and cannot be
responsible for these third-party websites or their content. Please be aware that the terms of
this Privacy Policy do not apply to these third-party websites or their content, or to any
collection of your Personal Data after you click on links to such third-party websites. We
encourage you to read the privacy policies of every website you visit. Any links to third-party
websites or locations are for your convenience and do not signify our endorsement of such
third parties or their products, content, or websites.
V. Third-Party Wallets.
To use our Service, you must use a third-party wallet which allows you to engage in
transactions on public blockchains. Your interactions with any third-party wallet provider are
governed by the applicable terms of service and privacy policy of that third party.
VI. Your Choices Regarding Information.
You have several choices regarding the use of information on our Services:
 Email Communications. We may periodically send you newsletters and/or emails
that directly promote the use of our Service or third parties’ goods and services. When
you receive newsletters or promotional communications from us, you may indicate a
preference to stop receiving these communications from us by following the
unsubscribe instructions provided in the email you receive or through the Notifications

preferences in your Settings page. Despite these preferences, we may send you
occasional transactional service-related informational communications.
 If you decide at any time that you no longer wish to accept Cookies from our Service
for any of the purposes described above, then you can instruct your browser, by
changing its settings, to stop accepting Cookies or to prompt you before accepting a
Cookie from the websites you visit. Consult your browser’s technical information. If
you do not accept Cookies, however, you may not be able to use all portions of the
Service or all functionality of the Service.
VII. Legal bases for the processing of your Personal Data
The Company may use Personal Data based on following legal bases:
 To enable the Company to enter into an agreement with you, after which The
Company will execute this agreement, such as but not limited to the agreement for the
delivery of The Company products and/or services;
 To enable The Company to meet its statutory obligations;
 We are always looking for ways to make our Services smarter, faster, more secure,
integrated and useful to you. It is in our legitimate business interests to continue to
maintain and improve Services. The processing is necessary for the purposes of the
legitimate interests pursued by The Company, including the interest to perform its
business activities, except where such interests are overridden by the interests of
fundamental rights and freedoms of the data subjects that require protection of
Personal Data. We use collective learnings about how people use our Services and
feedback provided directly to us to troubleshoot and to identify trends, usage, activity
patterns and areas for integration and improvement of the Services.
 Lastly, we may also use the personal data you provide to us for marketing purposes,
and in particular to offer you personalized offers.

* When we are processing personal data relating to you on the basis of your prior
consent to that processing, you may withdraw your consent at any time.
*Where we are using your information because we have a legitimate interest to do so,
you have the right to object.
VIII. Retention of Your Personal Data
We may retain your Personal Data as long as you continue to use the Service, have an account
with us, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy.
We may continue to retain your Personal Data even after you deactivate your account and/or
cease to use the Service if such retention is reasonably necessary to comply with our legal
obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms or other
agreements, and/or protect our legitimate interests. Where your Personal Data is no longer
required for these purposes, we will delete it.
IX. Security of Your Personal Data

The security of Your Personal Data is important to Us. We take necessary and proper
measures to protect your Personal Data, but remember that no method of transmission over
the Internet, or method of electronic storage is 100% secure. While We strive to use
commercially acceptable means to protect Your Personal Data, we cannot guarantee its
absolute security.
X. Transferring Data to Abroad
Within the scope of conducting our business activities, information and communication
technology applications and software (“IT Systems”) (“Yandex e-mail software, G-Cloud
Systems”) will be used. The infrastructure and databases of these services may be located
Due to the fact that the infrastructure of the IT Systems and databases that are used for
conducting communication activities and keeping your data safe may be located abroad, your
personal data will be transferred abroad “with your explicit consent”.
BITCI includes suitable technical, organizational and contractual safeguards (including
Standard Confidentiality Clauses), to ensure that such transfer is carried out in compliance
with applicable data protection rules of the relevant country.
XI. Your Rights
a. Your Rights under the CCPA. The CCPA provides California residents with specific
rights regarding their Personal Data. If You are a resident of California, You have the
following rights:
 The right to notice. You have the right to be notified which categories of Personal
Data are being collected and the purposes for which the Personal Data is being used.
 The right to request. Under CCPA, You have the right to request that we disclose
information to You about Our collection, use, sale, disclosure for business purposes
and share of Personal Data. Once we receive and confirm Your request, we will
disclose to You:
 The categories of Personal Data we collected about You
 The categories of sources for the Personal Data we collected about You
 Our business or commercial purpose for collecting or selling that Personal
 The categories of third parties with whom we share that Personal Data
 The specific pieces of Personal Data We collected about You
 If we sold Your Personal Data or disclosed Your Personal Data for a business
purpose, we will disclose to You:
 The categories of Personal Data categories sold
 The categories of Personal Data categories disclosed

 The right to say no to the sale of Personal Data (opt-out). You have the right to
direct Us to not sell Your Personal Data. To submit an opt-out request please contact
 The right to delete Personal Data. You have the right to request the deletion of Your
Personal Data, subject to certain exceptions. Once we receive and confirm your

request, we will delete (and direct Our Service Providers to delete) Your Personal
Data from our records, unless an exception applies. we may deny your deletion request
if retaining the information is necessary for us or our Service Providers to:
 Complete the transaction for which we collected the Personal Data, provide a
good or service that you requested, take actions reasonably anticipated within
the context of our ongoing business relationship with you, or otherwise
perform our contract with you.
 Detect security incidents, protect against malicious, deceptive, fraudulent, or
illegal activity, or prosecute those responsible for such activities.
 Debug products to identify and repair errors that impair existing intended
 Exercise free speech, ensure the right of another consumer to exercise their
free speech rights, or exercise another right provided for by law.
 Comply with the California Electronic Communications Privacy Act (Cal.
Penal Code § 1546 et. seq.).
 Engage in public or peer-reviewed scientific, historical, or statistical research
in the public interest that adheres to all other applicable ethics and privacy
laws, when the information's deletion may likely render impossible or
seriously impair the research's achievement, if you previously provided
informed consent.
 Enable solely internal uses that are reasonably aligned with consumer
expectations based on your relationship with us.
 Comply with a legal obligation.
 Make other internal and lawful uses of that information that are compatible
with the context in which you provided it.

 The right not to be discriminated against. You have the right not to be
discriminated against for exercising any of your consumer's rights, including by:
 Denying goods or services to you
 Charging different prices or rates for goods or services, including the use of
discounts or other benefits or imposing penalties
 Providing a different level or quality of goods or services to you
 Suggesting that you will receive a different price or rate for goods or services
or a different level or quality of goods or services.

b. Your Rights Under the GDPR
 Objection: Depending on the situation, you have the right to consent or object to the
processing of your Personal Data and the conditions under which this processing takes
 Access: You have the right to request from us, without constraint, at reasonable
intervals and without excessive delay or expense, i) a confirmation as to whether or
not Personal Data regarding you is being processed, ii) information on the purposes
for which Personal Data is processed, iii) the categories of Personal Data concerned,
and iv) the recipients or categories of recipients to whom the Personal Data is

disclosed. You have the right to receive, in an intelligible form, a communication of
the Personal Data being processed and of any available information as to the source(s).
Furthermore, you have the right to knowledge of the underlying logic of the automated
processing of Personal Data relating to you.
 Rectification, erasure, blocking or deletion: You, where appropriate, have the right
to rectification, erasure, blocking or deletion of your Personal Data that is not
processed in compliance with data protection laws and regulations, in particular when
the nature of the data is incomplete or inaccurate.
 Notification: You have the right to a notification to third parties to whom your
Personal Data has been disclosed, when you have been granted any rectification,
erasure, blocking or deletion as stated above, unless such notification proves to be
impossible or requires a disproportionate effort from us.
 Withdraw consent: where we are processing personal data relating to you on the
basis of your prior consent to that processing, you may withdraw your consent at any
 Complaint with relevant authority: You have the right to file a complaint with the
relevant data protection authorities.
XII. Children's Privacy
Our Service does not address anyone under the age of 18. We do not knowingly collect
personally identifiable information from anyone under the age of 18. If you are a parent or
guardian and you are aware that your child has provided us with Personal Data, please contact
Us. If we become aware that we have collected Personal Data from anyone under the age of
18 without verification of parental consent, we take steps to remove that information from our
If we need to rely on consent as a legal basis for processing your information and your
country requires consent from a parent, we may require Your parent's consent before we
collect and use that information
XIII. Applicable Law and Changes to this Privacy Policy
Laws of Switzerland shall apply to this Privacy Policy and the jurisdiction for any conflict
shall be the courts and enforcement offices of Zurich, Switzerland.
We may update our Privacy Policy from time to time. We will notify you of any changes by
posting the new Privacy Policy on this page
We will let you know via email and/or a prominent notice on our Service, prior to the change
becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this
Privacy Policy are effective when they are posted on this page.
XIV. Contact Us

If you have any questions about this Privacy Policy, You can contact us:
 By visiting this page on our website: [WEBSITECONTACTPAGE_URL]
 By sending us an email: [WEBSITECONTACTEMAIL]


Once you decided to create a User Account, we will send you the “Explicit Consent
Notification” below. You shall indicate your choice (accept/decline) by clicking and
accepting the notification. You may not use our Services if you do not accept the

Below I state my preference for recording, storing, preserving and transferring the following
personal data, which I conveyed to BITCI, to the relevant and authorized institutions and
organizations, if necessary and/or requested, for the purposes specified in the Privacy Notice,
preserving its accuracy and up-to-date form:
The transfer of my personal data in the category of identity and communication to abroad
through these systems, due to the fact that the infrastructure and databases of the IT Systems,
which are used for the purposes of carrying out communication activities and storing my
data, are abroad
I hereby declare that I read, understand and accept the Privacy Notice and the international
transfer of my personal data for the above-mentioned purposes;
Accept Disagree