Releaso Privacy Policy

Last update: 2 August 2024

This Privacy Policy ("Privacy Policy") governs the collection, use, and disclosure of Personal Data and other information when you use Releaso and establishes the legal relationship regarding personal data protection between you and Releaso (UAB "Releaso," company code 306774870, Vilnius, Republic of Lithuania), hereinafter referred to as "We" or the "Company."

We respect and value the privacy of every visitor to our website and the Users of our Services. We collect and use information solely in your best interests and in accordance with your rights and our obligations under data protection laws.

This Privacy Policy is part of the Terms of Use. The definitions used in this Privacy Policy have the same meanings as in the Terms of Use unless otherwise specified in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use Releaso.

By using Releaso, you confirm that you agree with the Privacy Policy and accept the Terms of Use. By providing us with your personal data, you thereby consent to the collection, storage, use, and disclosure of your personal data in accordance with this Privacy Policy.

1. Definitions

1.1 Data Controller — refers to the entity that determines the purposes for which and the means by which any personal data is processed. For the purposes outlined in this Privacy Policy, we are the Data Controller of your Personal Data. If you have any questions, please contact us at [email protected].

1.2 Data Subject (You) — refers to any individual who uses Releaso and is the subject of the collection of Personal Data.

1.3 Personal Data — refers to data about any individual who can be identified by that data.

1.4 Processing — refers to any operation or set of operations performed on Personal Data, such as collection, recording, organization, structuring, storage, adaptation, or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction, whether or not by automated means.

1.5 Third Party — refers to any natural or legal person, public authority, agency, or body other than the Data Subject, which is authorized to process Personal Data under the direct authority of the Data Controller or Data Processor.

1.6 Website — refers to the website operated by Releaso and accessible at https://goreleaso.com/.

2. Legal Grounds for Processing Your Personal Data:

2.1 The processing of your Personal Data is necessary for the performance of an Agreement with you, the User of our Website and Services — General Data Protection Regulation (GDPR), Article 6(1)(b);

2.2 The processing of your Personal Data is necessary for compliance with legal obligations — GDPR, Article 6(1)(c);

2.3 The processing of your Personal Data is necessary for the purposes of legitimate interests pursued by Releaso as well as by you as the User and Data Subject — GDPR, Article 6(1)(f). In particular:

2.3.1 To ensure the security of Releaso's systems and for monitoring performance, identifying errors, and troubleshooting;

2.3.2 To improve the performance and usability of Releaso.

3. Purposes of Collecting Personal Data

3.1 To maintain and provide you with Releaso / the Website / our Services;

3.2 To provide, maintain, deliver, or improve our Website and Releaso, which is provided through the software;

3.3 To increase the number of Services available to you, when possible and appropriate;

3.4 To comply with legal and regulatory requirements, adhere to our policies and obligations, including, but not limited to, disclosing information in response to any requests from law enforcement and/or regulatory authorities in accordance with applicable laws, regulations, rules, directives, judicial or governmental orders;

3.5 To provide you with information or Services upon your request;

3.6 To carry out actions for which we have obtained your consent, as well as for any other reason and to achieve any purpose specified in the purposes of collecting Personal Data.

Types of Personal Data	Time and Method of Collection	Purpose and/or Action	Legal Basis for Processing
Phone Number	During the registration/sign-in/verification process	To register you as a new customer / To secure your Account with two-factor authentication	Consent of the Data Subject / Performance of the Agreement
Email	During the registration/sign-in/verification process	To register you as a new customer / To secure your Account with two-factor authentication	Consent of the Data Subject / Performance of the Agreement
Documents for Identity Verification, Subject to Your Consent for Their Provision: Government-issued identification (passport, driver’s license, ID card, passport number, information provided in the driver’s license, or taxpayer identification number); Proof of address; Photo and video.	During the verification process	To comply with KYC requirements, for the purpose of verifying the User’s identity	Consent of the Data Subject / Performance of the Agreement
Data About Your Device and Use of the Website: Information sent by your device when using Releaso/Website; Information about your use of Releaso/Website, including the type and version of the browser you are using; Information about the device you are using, including hardware model, operating system and version, as well as unique device identifiers, etc.; The IP address from which you access our Website; URLs of websites from which you were redirected to our Website, as well as URLs of websites you visit from our Website/source from which you access Releaso (if applicable); Public data that you have imported into Releaso; Public blockchain network addresses; Unique User hash; Other non-personalized traffic data.	During the use of Releaso / Website / our Services	For the purpose of securing the User’s Account and complying with AML/CFT policy requirements. We also use this data to protect the User from automated abuses such as spam, phishing, and DDoS attacks.	Consent of the Data Subject / Performance of the Agreement
Actions Performed in the User Account: Trading activity; Transaction history; Order conditions; Created orders; User Account status and notifications; Default currency and language, time zone.	During the use of Releaso / Website / our Services	For the purpose of improving the quality of the Services provided. You can easily delete any cookie files created in the appropriate folder by going to your browser settings. You can set your browser to automatically refuse all cookies or to notify you where they are sent.	Compliance with legal obligations / Performance of the Agreement
Cookies	During the use of Releaso / Website	For the purpose of contacting you, responding to your inquiries, comments, and/or suggestions, and improving the level of Services provided to you. We retain this data for as long as necessary to provide you with qualified technical support.	Consent of the Data Subject / Performance of the Agreement
Avatar and Nickname	During the registration/sign-in/verification process	For the purpose of securing the User’s Account and complying with AML/CFT policy requirements. We also use this data to protect the User from automated abuses such as spam, phishing, and DDoS attacks.	Consent of the Data Subject / Performance of the Agreement

4. KYC Data Ecosystem (Know Your Customer). Disclosure of Personal Data

4.1 Our primary principle in the collection and storage of Personal Data is to facilitate the use or improve the quality of our Services and offerings.

4.2 To simplify your use of Releaso Services, we have created a database within the KYC ecosystem, the creation and use of which fully complies with the General Data Protection Regulation (GDPR), legislation, and Data Protection Rules.

4.3 We ensure the protection of the KYC ecosystem Database through appropriate physical, technological, and organizational security measures and precautions. Access to the KYC ecosystem Database is restricted by setting specific access rights.

4.4 We do not sell your Personal Data or transfer it to third parties, except as provided in this Privacy Policy. Your Personal Data may be disclosed only to the extent expressly permitted by applicable law and this Privacy Policy.

4.5 We contract qualified specialists (third parties) to ensure the security and legality of the collection and processing of Personal Data that is part of the KYC ecosystem Database.

4.6 The placement of your Personal Data in the KYC ecosystem Database, as well as its transfer to third parties, is carried out exclusively with your consent, which we request from you. By providing your consent, you agree to the transfer of your Personal Data to third parties in accordance with the agreement concluded with the service provider of those third parties. If you do not provide your consent, you are prohibited from using Releaso.

4.7 We may provide your Personal Data to the following third parties:

4.7.1 External services or authorities when such data transfer is necessary to fulfill our applicable legal obligations or to protect your vital interests;

4.7.2 Other third parties, including foreign legal entities, to ensure the provision of services to you.

4.8 When disclosing your Personal Data, we take all necessary measures to ensure that the specified third parties commit to maintaining confidentiality and safeguarding your Personal Data. Disclosure is carried out in accordance with legal requirements, including the conclusion of data processing agreements with relevant third parties to ensure data processing strictly in accordance with our instructions, applicable laws, regulations, and for the purpose we have set, as well as to ensure appropriate security measures.

4.9 Your data, both public and personal, cannot be sold, exchanged, transferred, or provided to another company without your consent, regardless of the reason, except for the provision of the services you have requested and the improvement of the quality of services we provide.

5. Storage/Deletion of Your Personal Data

5.1 We retain your data no longer than necessary for the purpose of data collection and in compliance with legal requirements. When Personal Data and other information are no longer needed, we initiate the procedure for their destruction, deletion, erasure, or conversion into an encrypted format.

5.2 All Personal Data can be deleted by you at your own discretion. You can withdraw your consent and/or request the deletion of your Personal Data at any time by contacting us at [email protected].

5.3 In cases provided by law, we reserve the right to retain/process Personal Data for a specific purpose of storage/processing without a time limitation on storage and processing.

5.4 Withdrawing your consent and/or deleting your Personal Data may prevent you from using certain features of Releaso.

5.5 We will delete your data without undue delay if one of the following grounds applies:

5.5.1 Personal Data is no longer necessary for the purposes for which it was collected or processed;

5.5.2 You have withdrawn your consent, on which the data processing was based (in the absence of other legal grounds for processing);

5.5.3 You object to the processing of your Personal Data (in the absence of other, more compelling and lawful grounds for processing);

5.5.4 Personal Data has been processed unlawfully;

5.6 Personal Data must be deleted if this is necessary to comply with a legal obligation under the laws of the Union or a member state to which the Data Controller is subject.

5.7 Your Personal Data may be retained if it is necessary to comply with a legal obligation to which we are subject or for the protection of your vital interests or the vital interests of another individual, in accordance with the General Data Protection Regulation (GDPR), Article 6(1)(c).

6. Security of Personal Data

6.1 Data security is of paramount importance to us. To protect and secure your Personal Data collected through the website and mobile application, appropriate physical, electronic, and managerial procedures have been implemented. The actions we take to ensure the security and protection of your data include:

6.1.1 Two-factor authentication (2FA);

6.1.2 Access control;

6.1.3 The ability to continuously ensure the confidentiality, integrity, availability, and stability of our Services;

6.1.4 The ability to promptly restore access to Personal Data in the event of a physical or technical failure.

6.2 If you suspect that your Personal Data (especially data related to your User Account and/or password) has been compromised, please immediately block your Account and contact us at [email protected].

7. International Transfer of Personal Data

7.1 Certain features and requirements of our service may involve the transfer of your data to third parties who are service providers located outside the European Economic Area (EEA). If the country where such service providers are located does not provide an adequate level of protection as stipulated by the General Data Protection Regulation (GDPR), such data transfer will be carried out in accordance with the standard data protection clauses adopted by the European Commission or through another appropriate safeguard mechanism.

8. Rights of the Data Subject

8.1 You have the right to:

8.1.1 Obtain confirmation as to whether or not your Personal Data is being processed by us, and access your data if such processing is taking place. We will provide you with a copy of your Personal Data;

8.1.2 Modify and correct your Personal Data at any time, and therefore you are responsible for the accuracy of the provided Personal Data;

8.1.3 Request that we transfer your Personal Data, as well as the right to ask us to restrict the processing of your Personal Data and/or delete it if there is no legal obligation to retain the data;

8.1.4 Object to the processing of your Personal Data and/or withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal;

8.1.5 Have your Personal Data deleted.

8.2 The legal grounds for processing personal data in the European Economic Area (EEA) are set out in the General Data Protection Regulation (GDPR). We strive to take reasonable steps to allow you to correct, modify, delete, or limit the use of your Personal Data.

8.3 If you are a resident of the European Economic Area (EEA), you have certain data protection rights as specified in the GDPR.

8.4 The right to access, update, or delete the information we have about you. Whenever possible, you can access, update, or request the deletion of your Personal Data directly. If you are unable to perform these actions yourself, please contact us.

8.5 The right to rectification. You have the right to have your information corrected if it is inaccurate or incomplete.

8.6 The right to object. You have the right to object to the processing of your Personal Data.

8.7 Right to Restriction. You have the right to request that we restrict the processing of your Personal Data.

8.8 Right to Withdraw Consent. You also have the right to withdraw your consent to the processing of Personal Data at any time, which we have relied upon.

8.9 You can exercise your rights by contacting us at [email protected].

8.10 If you wish to obtain information about your Personal Data that we hold about you and would like it to be removed from our systems, please contact us at [email protected].

8.11 You have the right to lodge a complaint with the relevant authorities. For more information, please contact your local Data Protection Authority in the European Economic Area (EEA).

9. Children's Privacy Policy

9.1 The Wallet is not intended for use by individuals under the age of 18 ("Children").

9.2 We do not knowingly collect Personal Data from individuals under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us at [email protected].

9.3 If we become aware that we have collected Personal Data from Children without parental consent verification, we will take the necessary steps to delete that information.

10. Amendments

10.1 We may change, modify, delete, or supplement this Privacy Policy at any time.

10.2 Any such changes will take effect upon being published on the Website or in the mobile application. The effective date indicated at the top of the Privacy Policy informs you of the latest version of the Privacy Policy.

10.3 Your continued use of the Wallet and/or the Website signifies your acceptance of such changes and your consent to the processing of Personal Data in accordance with the latest version.

11. Questions and Complaints

11.1 Any questions related to this Privacy Policy, the collection, use, and disclosure of Personal Data, or access to your Personal Data required by law (or would be the subject of such consideration if the storage was conducted in the relevant EU member state) should be directed to [email protected].

11.2 If you wish to file a complaint regarding the processing of your Personal Data, please first contact us at [email protected], and we will do our best to address your request as quickly as possible.