The types of Personal Information we collect and how it may be used;
How and why we may disclose your Personal Information to third parties;
The transfer of your Personal Information within and outside of the European Economic Area (“EEA”);
Your right to access, correct, update, and delete your Personal Information;
The security measures we use to protect and prevent the loss, misuse, or alteration of Personal Information; and
Embily’s retention of your Personal Information.
COLLECTION AND USE OF PERSONAL INFORMATION
PERSONAL INFORMATION WE COLLECT
We collect the Personal Information you provide directly to us when you open an Embily Account, perform any transactions on the Embily Platform, or use other Embily Services. This may include:
Contact information, such as name, home address, and email address.
Account information, such as username and password.
Financial information, such as bank account numbers, bank statement, and transaction information.
Identity verification information, such as images of your government issued ID, passport, national ID card, or driving license.
Residence verification information, such as Utility bill details or similar information.
We also automatically collect certain computer, device, and browsing information when you access the Embily website or use Embily Services. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals. This information may include:
Computer or mobile device information, including IP address, operating system, browser type.
Website usage information.
The Embily site is using cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyze trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our Site are most visited and difficulties our visitors may experience in accessing our Site. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We use third-party service provider(s), to assist us in better understanding the use of our Site. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general interaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors’ interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our service provider(s) is/are contractually restricted from using the information they receive from our Site other than to assist us.
HOW WE USE YOUR PERSONAL INFORMATION
We may use your Personal Information to:
Process your Embily transactions. We will process your Personal Information only for the purpose(s) for which it has been provided to us.
Personalise your Embily Services experience.
Analyse Embily website usage, and improve our website and website offerings.
Help us respond to your customer service requests and support needs.
Contact you about Embily Services. The email address you provide may be used to communicate information and updates related to your use of the Embily Services. We may also occasionally communicate company news, updates, promotions, and related information relating to similar products and services provided by Embily.
Administer a contest, promotion, survey or other site features as will be more explained on the website.
We do not perform behavioural tracking of a customer’s activities on our Website or across different Websites, nor do we allow third-party data collection through our Service.
If you wish to stop receiving marketing communications from us, please contact us at [email protected] to opt-out.
DISCLOSING AND TRANSFERRING PERSONAL INFORMATION
We may disclose your Personal Information to third parties and legal and regulatory authorities, and transfer your Personal Information outside the EEA, as described below.
DISCLOSURES TO THIRD PARTIES
DISCLOSURES TO LEGAL AUTHORITIES
We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities when:
Compelled by subpoena, court order, or other legal procedure.
We believe that the disclosure is necessary to prevent physical harm or financial loss.
Disclosure is necessary to report suspected illegal activity.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
We store and process your Personal Information in data centres around the world, wherever Embily facilities or service providers are located. As such, we may transfer your Personal Information outside of the EEA. Such transfers are undertaken in accordance with our legal and regulatory obligations.
Occasionally, the Embily website may provide references or links to other websites (“External Websites”). We do not control these External Websites third party sites or any of the content contained therein. You agree that we are in no way responsible or liable for External Websites referenced or linked from the Embily website, including, but not limited to, website content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to, or arising from those sites. External Websites have separate and independent privacy policies. We encourage you to review the policies, rules, terms, and regulations of each site that you visit. We seek to protect the integrity of our site and welcome any feedback about External Website information provided on the Embily website.
ACCESS RIGHTS TO PERSONAL INFORMATION
SECURITY OF PERSONAL INFORMATION
We use a variety of security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, theft, unauthorised access, misuse, alteration or destruction. These security measures include, but are not limited to:
Password protected directories and databases.
Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely.
PCI Scanning to actively protect our servers from hackers and other vulnerabilities.
All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorised Embily personnel are permitted access to your Personal Information, and this personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.
RETENTION OF PERSONAL INFORMATION
Personal Information. Information that identifies an individual, such as name, address, e-mail address, trading information, and banking details. “Personal Information” does not include anonymised and/or aggregated data that does not identify a specific user.
Service(s). The technological platform, functional rules and market managed by Embily FZ LLC to permit Members to perform conversion transactions of Digital Assets.
Transaction. Includes the following:
The conversion of Digital Assets into currencies deposited by Members on their account (“Conversion Transaction”);
The purchase of ancillary products (“Purchase Transactions”).