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    Privacy Policy for Easy Mining Service

    Effective Date:

    [Insert Date]

    Vision Dealers s.r.o. ("we," "us," or "our"), a company registered under the laws of the Czech Republic with company ID 1107526, is committed to ensuring the lawful, transparent, and secure processing of personal data in compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), Act No. 110/2019 Coll., on the Processing of Personal Data, and other relevant Czech legal regulations. This Privacy Policy outlines the principles, purposes, and practices of data processing conducted in connection with the Easy Mining Service ("Service") on our _____ ("Platform").

    This Policy along with our Terms & Conditions ("Terms") provide the basis for the collection, use, processing, and protection of your information. This Privacy Policy also explains what options our users have with regards to their personal information. For more information on the definitions of terminology used in this Policy please refer to our Terms.

    Personal information means any data relating to an identified or identifiable natural person. This Policy applies to information we collect when you access or use services available on the Platform, or otherwise interact with us as described below. We are compliant with applicable laws in the countries in which we operate. By using the Platform or Service or interacting with us as described below, you confirm that you are aware of this Privacy Policy.

    1.

    Data Controller

    The data controller responsible for the processing of personal data is:

    • Name of the company: Vision Dealers s.r.o.
    • Registered Office: Říční 456/10, Malá Strana, 118 00 Praha 1
    • Company ID: 1107526
    • Contact Email: michal@______.com
    • Contact Phone: [Your Phone Number]

    For inquiries related to this Privacy Policy, please contact us using the details above.

    2.

    Personal Data We Collect

    We collect and process personal data to provide, improve, and secure the Service. The types of data collected are detailed below:

    • 2.1. Data Provided Directly by Users
      • Account Information: Full name, email address, telephone number, date of birth, and any other data provided during account registration.
      • Verification Data: Documents required for Know Your Customer ("KYC") and Anti-Money Laundering ("AML") compliance, such as government-issued identification, proof of address, and photographs.
      • Payment Data: Cryptocurrency wallet addresses, transaction identifiers, and financial details related to the use of the Service.
    • 2.2. Data Collected Automatically
      • Technical Information: IP address, device information, browser type, operating system, and log data.
      • Usage Data: Information regarding Service usage, including transaction history and session activity.
    • 2.3. Data from Third Parties
      • We may receive additional personal data from external entities involved in verification, analytics, or blockchain analysis, as permitted by law.
    3.

    Purpose and Legal Basis of Processing

    We process personal data for specific and lawful purposes, based on the following legal grounds as set out in Article 6(1) of the GDPR:

    • 3.1. Performance of a Contract (Art. 6(1)(b) GDPR):
      • Creating and managing user accounts.
      • Facilitating transactions and providing access to mining services.
      • Verifying identity and ensuring compliance with contractual obligations.
    • 3.2. Legal Obligations (Art. 6(1)(c) GDPR):
      • Compliance with AML and counter-terrorist financing ("CTF") requirements under Czech law.
      • Meeting regulatory and tax obligations.
      • Responding to lawful requests from regulatory or law enforcement authorities.
    • 3.3. Legitimate Interests (Art. 6(1)(f) GDPR):
      • Improving and optimizing the Service.
      • Preventing fraud, unauthorized access, or misuse of the Service.
      • Conducting analytics and security monitoring.
    • 3.4. Consent (Art. 6(1)(a) GDPR):
      • Sending marketing communications, provided users have given explicit consent.
    4.

    Sharing of Personal Data

    We ensure that personal data is only shared with authorized parties, strictly in accordance with applicable laws:

    • 4.1. With Third-Party Service Providers:We engage trusted third parties for:
      • Identity Verification: External providers specializing in KYC and AML processes.
      • Payment Processing: Cryptocurrency transaction management and blockchain analysis.
      • Hosting and IT Services: Secure storage and processing of data.
    • 4.2. For Legal and Regulatory Compliance:We may disclose personal data to:
      • Regulatory authorities to fulfill statutory obligations under Czech AML laws.
      • Law enforcement agencies pursuant to valid subpoenas, court orders, or similar legal requirements.
      • Counterparties involved in investigations related to fraudulent or unlawful activities.
    • 4.3. In Connection with Business Transactions:In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the acquiring entity, provided such transfer is conducted in compliance with GDPR.
    5.

    Data Retention

    We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or to comply with applicable legal obligations:

    • Account Data: Retained until account closure and settlement of all obligations.
    • Transaction Data: Retained for a minimum of 5 years, as required under Czech AML regulations.
    • Verification Data: Retained for 5 years following the closure of an account, for compliance purposes.

    After the retention period, personal data will be securely deleted or anonymized.

    6.

    Data Subject Rights

    Under GDPR and Czech data protection laws, users have the following rights regarding their personal data:

    • 6.1. Right to Access (Art. 15 GDPR): Request a copy of the personal data we hold and information about how it is processed.
    • 6.2. Right to Rectification (Art. 16 GDPR): Request correction of inaccurate or incomplete data.
    • 6.3. Right to Erasure (Art. 17 GDPR): Request deletion of personal data, subject to legal retention requirements.
    • 6.4. Right to Restrict Processing (Art. 18 GDPR): Request that processing of personal data be restricted under certain conditions.
    • 6.5. Right to Data Portability (Art. 20 GDPR): Request the transfer of personal data in a structured, machine-readable format.
    • 6.6. Right to Object (Art. 21 GDPR): Object to data processing based on legitimate interests or direct marketing.
    • 6.7. Right to Lodge a Complaint: File a complaint with the Office for Personal Data Protection ("Urad pro ochranu osobnich udaju") in the Czech Republic.
    7.

    Data Security

    We implement technical and organizational measures to ensure the confidentiality, integrity, and availability of personal data, including:

    • Data encryption during storage and transmission.
    • Regular security audits and penetration testing.
    • Strict access controls and two-factor authentication.
    • Employee training and internal privacy policies.
    8.

    International Data Transfers

    All data processing occurs within the European Economic Area ("EEA"). In cases where data is transferred outside the EEA, we ensure adequate safeguards, such as Standard Contractual Clauses, to protect personal data in compliance with GDPR.

    9.

    Cookies

    Cookies are small text files placed on your computer by websites that you visit. They are used to make websites work more efficiently and to provide information to the site owners. We use both session and persistent cookies. Session cookies expire when you log out or close your browser, while persistent cookies remain until you delete them or they expire. Most web browsers accept cookies by default. You are free to decline cookies, but disabling them may affect the functionality of the Mining Services.

    Additionally, we may use persistent cookies solely for identity verification and fraud prevention purposes. For more information on how to block, delete, or disable cookies, please refer to your browser instructions or contact us.

    10.

    Updates to This Policy

    We reserve the right to amend this Privacy Policy to reflect changes in legal requirements or our data processing practices. Updates will be posted on our website, and significant changes will be communicated directly to users.

    11.

    Contact Information

    For further information about this Privacy Policy or to exercise your rights, please contact our Data Protection Officer:

    • Email: [Your Email Address]
    • Phone: [Your Phone Number]
    • Address: Říční 456/10, Malá Strana, 118 00 Praha 1

    You also have the right to contact the Office for Personal Data Protection ("Urad pro ochranu osobnich údaju") at www.uoou.cz.