Dated: October 14, 2019
A. What information do we collect?
We collect Personal Information that You provide voluntarily when You register on to the SITE or offer/procure any Services through the SITE or make any inquiries through the SITE or communicate with Bleumi (including customer service representatives, service providers or other employees) by email, telephone, letter or other methods, comment on blog posts, or subscribe for newsletters or other information services, or report a problem with our site, or otherwise contact us.
We will collect the following information that you provided through the SITE:
- Email address and password – when you Sign Up directly on the SITE
- Ethereum wallet address – when you provide Ethereum wallet address on the SITE
We do not collect any Sensitive Personal Information relating to topics such as confidential medical facts, racial or ethnic origins, political or religious beliefs or sexuality.
You may have the opportunity to create a profile, which consists of information about you, and may include personal information, photographs and other information, including your username (“Profile”). If, in any case, you believe that an unauthorized profile has been created about you, you can request for it to be removed by contacting us at firstname.lastname@example.org
To request removal of your personal information from our website, contact us at email@example.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
B. How do we use your information
We use the information You voluntarily provide for the following purposes:
- To process and fulfill your queries regarding services offered on the SITE and/or contact you
- To answer your inquiries about our services
- To contact you with administrative communications and marketing or promotional materials (on behalf of
Bleumi or third parties) and other information that may be of interest to you, to which you have
We use information that we collect about you:
- To enable your seamless use of the SITE
- To contact visitors of the SITE when necessary
- To resolve any issues with the SITE
- To efficiently manage the SITE which includes analysis, research, statistical and survey uses, together with
testing and troubleshooting
- To ensure the SITE is safe and secure by monitoring activities within the context of continual process
- To improve the algorithms, marketing efforts and enhance the overall service levels and offerings
Bleumi may use non-personal information for the purposes mentioned above as well as to monitor the SITE and
provide a better online experience to the users.
C. How long do we retain your information
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
The following information collected is necessary for the functioning of the account. The data is retained until a
“Delete Account” request is received from the user.
The following information is ONLY collected when the SITE fails to behave as intended. Once the cause has been
identified & remediated, the information is promptly deleted.
- IP Address
- Browser Name & Version
- OS NaIP Addressme & Version
- URL being browsed (only on pay.bleumi.com domain)
- Error information
The following information is captured when You submit a support ticket via the widget on the SITE or through the
support portal. Once the ticket is closed, the information is automatically deleted within three months.
- Email Address
- Support case description
- Support case comments
D. When and with whom do we share your Personal Information
Your personal information will not be shared with any third party except as mentioned here:
- When Bleumi is required by law to share the information in situations such as
- when We suspect a violation of the Terms
- co-operating with law enforcement agencies in response to any judicial order
- co-operating with an investigation on matters related to public safety, illegal activities,
suspected fraud, threats to the physical safety of any person, etc., as may be permitted by law.
- With the following third parties on a strictly need to know basis, solely for providing services about the
- We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, in
connection with a merger, acquisition, reorganisation or sale of assets (including, in each case, as part of
the due-diligence process with any potential acquiring entity) or in the event of bankruptcy. You will be
notified via email and a prominent notice on our website of any change in ownership or uses of your personal
information, as well as any choices you may have regarding your personal information.
Transfer of Information
If you are located outside the United States and choose to provide information to us, We transfer Personal
Information to the United States for processing. The information collected in connection with the SITE may be
processed and stored, in any country where We engage service providers, where the data protection laws may be
different from that applicable in the United States of America or that of the country where you reside. By
making use of the SITE, You acknowledge and accept the storage, transfer and processing of information, outside
of Your country of residence. However, when we transfer your information, we will protect it as described in
E. How do we keep your Information Secure
Access to personal information is limited to employees who We reasonably believe to require access to such information for them to perform their designated functions in relation to providing services to You. We use commercially reasonable safeguards to preserve the integrity and security of all information collected through or in connection with the SITE. To protect your privacy and security, we take reasonable steps (such as requesting a magic link) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your magic link and account information, and for controlling access to your email communications from Bleumi. Notwithstanding the foregoing measures, Although we will use reasonable efforts to secure network communications and the SITE, we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure, or that information on the SITE may not be accessed, disclosed, altered, or destroyed.
Cookies are small text files that are used by a website for various purposes.
Certain cookies are essential to the proper functioning of the site and must be enabled at all times. Non-essential cookies (e.g. Analytics, Performance tracking, etc) can be disabled should you choose to do so.
To ensure you are not tracked, we recommend one of the following:
- Set your browser to do not track – we respect this signal regardless of the presence of a cookie.
- Set your browser to accept 3rd party cookies, and then opt out as normal. This will also ensure we do not
track your data.
Cookie declaration last updated on : April 01, 2019.
THIRD PARTY PROCESSORS
We DO NOT use or sell the information gathered from the following processors below for any marketing purpose. The
third party cookies are listed below.
- Google Analytics – We use Google Analytics to monitor the website traffic. This helps us diagnose errors and
optimize the site based on traffic flow.
G. Third Party Website
Identity theft and the practice currently known as “phishing” are of great concern to Bleumi. Safeguarding
information to help protect you from identity theft is a top priority. We do not and will not, at any time,
request your credit card information, your account ID, login password, social security number or national
identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information
about phishing, visit the Federal Trade Commission’s website at consumer.ftc.gov/articles/0003-phishing.
I. Policy Toward Children
This Site is not directed to persons under 18. We do not knowingly collect personally identifiable information from children under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact our support team immediately. If we become aware that a child under 16 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files.
J. User Rights
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”) to receive a copy
of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you to have any incomplete or inaccurate data we
hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data to seek deletion or removal of personal data where there is no good
reason for Us continuing to process it. You also have the right to ask us to delete or remove your personal
data where you have successfully exercised your right to object to processing (see below), where we may have
processed your information unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your request of erasure for specific
legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a
third party) and there is something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the
right to object where we are processing your personal data for direct marketing purposes including
profiling. In some cases, we may demonstrate that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
- Request restriction of processing of your personal data to suspend the processing of your personal data in
the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data
is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use
of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third
party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that
this right only applies to automated information which you initially provided consent for us to use or where
we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. This will not
affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide certain products or services to you. We will advise you if this is
the case at the time you withdraw your consent.
- Lodge a complaint with a supervisory authority responsible for data protection if you consider that our
processing of your personal information infringes data protection law
Except for the right to withdraw consent which you can exercise through the SITE, for exercising any other rights
specified herein above, please contact our data controller at firstname.lastname@example.org.
L. Contacting Us