Last updated: October 12, 2017
How we collect information about you
When you visit the Coinsource website, use Coinsource Services, or use third-party services which use the Coinsource application programming interface (“API”), we collect information sent to us through your computer, mobile phone, or other access device. This information may include your IP address, device information including, but not limited to, identifier, device name and type, operating system, location, mobile network information, and standard web log information, such as your browser type, traffic to and from our site, and the pages you accessed on our website. You must be at least 18 years old, or of the applicable age of majority, in order to use Coinsource Services.
If you create an account or use Coinsource Services, we, or our affiliates vendors acting on our behalf may collect the following types of information:
- Contact information – your name, address, phone, email, Skype ID, and other similar information; and
- Financial information – the full bank account and routing numbers and/or credit card numbers that you link to your Coinsource Account or input when you use paid Coinsource Services. If you do not use the Coinsource Conversion Service, you may opt out of providing this information.
- Biometric information – in accordance with Coinsource’s Biometric Information Security Policy.
When you use Coinsource Services, we collect information about your transactions and/or your other activities on our website and we may continuously collect information about your computer, mobile device, or other access device for fraud prevention purposes, to monitor for possible breach of your Coinsource Account, and to identify any malicious software or other activity that may harm Coinsource or its users.
When you access our website or content or use our application or Coinsource Services, we or companies we work with may place small data files called cookies or pixel tags on your computer or other device. We use these technologies to:
- Recognize you as a Coinsource customer;
- Customize Coinsource Services, content, and advertising;
- Measure promotional effectiveness; and
- Collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.
We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire.
We also use Local Shared Objects, commonly referred to as “Flash cookies,” to help ensure that your account security is not compromised, to spot irregularities in behavior to help prevent fraud, and to support our sites and services.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of our website. The help section of most browsers or browser add-ons provides instructions on blocking, deleting, or disabling cookies.
How we protect and store personal information
Throughout this policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been anonymized so that it does not identify a specific user. Coinsource takes reasonable precautions, as described herein, to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
We store and process your personal and transactional information, including certain payment information on our computers in the United States and elsewhere in the world where Coinsource facilities or our service providers are located, and we protect it by maintaining physical, electronic, and procedural safeguards in compliance with applicable U.S. federal and state regulations. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted off-site by a payment vendor in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to Coinsource staff.
We store our customers’ personal information securely throughout the life of the customer’s Coinsource Account. Coinsource will retain your personal information for a minimum of five years or as necessary to comply with our legal obligations or to resolve disputes.
How we use the personal information we collect
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:
- Provide Coinsource Services and customer support you request;
- Process transactions and send notices about your transactions;
- Resolve disputes, collect fees, and troubleshoot problems;
- Prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;
- Customize, measure, and improve Coinsource Services and the content and layout of our website and applications;
- Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; and
- Compare information for accuracy and verify it with third parties.
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or Coinsource Services may not be available to you.
We will not sell or rent your personal information to third parties. We may combine your information with information we collect from other companies and use it to improve and personalize Coinsource Services, content, and advertising.
How personal information is shared with other Coinsource users
To process your payments, we may share some of your personal information with the person or company to which you transfer or from which you receive bitcoin. Your contact information, date of sign-up, the number of payments you have received from verified Coinsource users, and whether you have verified control of a bank account are provided to other Coinsource users with whom you transact through Coinsource In addition, this and other information you disclose to Coinsource may be shared with third parties who may provide, upon your authorization, ancillary services which access your Coinsource Account. Unless you have agreed to it, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using Coinsource services.
If you use your Coinsource Account to transfer bitcoin in connection with the purchase or sale of goods or services, we or you may also provide the seller with your shipping address to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have agreed to it. If an attempt to transfer bitcoin to your seller fails or is later invalidated, we may also provide your seller with details of the unsuccessful transfer. To facilitate dispute resolutions, we may provide a buyer with the seller’s address so that goods can be returned to the seller.
In connection with a bitcoin transfer between you and a third party, including merchants, a third party may share information about you with us, such as your email address or mobile phone number which may be used to inform you that a transfer has been sent to or received from the third party. We may use this information in connection with such transfers to confirm that you are a Coinsource customer, that bitcoin transfers are enabled, and/or to notify you that you have received bitcoin. If you request that we validate your status as a Coinsource customer with a third party, we will do so. You may also choose to send bitcoin to, or request bitcoin from an email address. In such cases, your user name will be displayed in an email message notifying the user of the designated email address of your action. Please note that merchants you interact with may have their own privacy policies, and Coinsource is not responsible for their operations, including, but not limited to, their information practices.
How we share personal information with other parties
We may share your personal information with:
- Service providers under contract who help with parts of our business operations such as fraud prevention, bill collection, marketing, and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit;
- Third party identity verification services in order to prevent fraud. This allows Coinsource to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used by the service providers solely in connection with provision of identity verification and fraud prevention services;
- Financial institutions with which we partner;
- Companies or other entities that purchase Coinsource assets pursuant to a court-approved sale under U.S. Bankruptcy law;
- Law enforcement, government officials, or other third parties when:
- We are compelled to do so by a subpoena, court order, or similar legal procedure; or
- We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement; and
- Other third parties with your consent or direction to do so.
Coinsource will not sell or rent any of your personal information to third parties and only shares your personal information with third parties as described in this policy. Before Coinsource shares your information with any third party that is not acting as an agent to perform tasks on behalf of and under the instructions of Coinsource, Coinsource will enter into a written agreement requiring that the third party to provide at least the same level of privacy protection as required hereunder.
If you establish a Coinsource account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a Coinsource website) will be shared with the owner of the third-party website or application and your information may be subject to their privacy policies.
In general, we will notify you of material changes to this policy by updating the last updated date at the top of this page, and we will provide you with explicit notice of material changes as required by law. We recommend that you visit this page frequently to check for changes.
How you can access or change your personal information
How you can contact us about privacy questions
If you have questions or concerns regarding this policy, or if you have a complaint, you should first contact us at firstname.lastname@example.org.
For Texas Users Only: If you still have an unresolved complaint regarding the company’s money transmission or currency exchange activity, please direct your complaint to: Texas Department of Banking, 2601 North Lamar Boulevard, Austin, Texas 78705, 1-877-276-5554 (toll free), www.dob.texas.gov.
BIOMETRIC INFORMATION SECURITY POLICY
1.1. This Biometric Information and Security Policy (“Policy”) defines Coinsource’s policy and procedures for collection, use, safeguarding, storage, retention, and destruction of biometric information collected by Coinsource.
1.2. Coinsource uses biometric identification systems to verify customer identity in allowing a customer to create an account with Coinsource. Coinsource collects, stores, and uses customer biometric information for the purpose of maintaining a customer’s account and identity verification.
2.1. “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.
2.2. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color.
3.1. Coinsource’s policy is to protect and store biometric information in accordance with applicable standards and laws, including, but not limited to, the Illinois Biometric Information Privacy Act and the Texas Business and Commerce Code Section 503.001.
3.2. Coinsource will not collect or otherwise obtain an individual’s biometric information without prior written consent of the individual. Coinsource will inform the individual of the reason his or her biometric information is being collected and the length of time the information will be stored.
3.3. Coinsource will not sell, lease, trade, or otherwise profit from an individual’s biometric information.
3.4. Coinsource will not disclose an individual’s biometric information unless: (1) the individual consents, (2) the disclosure is necessary to complete a financial transaction requested or authorized by the individual, (3) the disclosure is required by State or federal law or municipal ordinance, or (4) the disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
3.5. Coinsource will store, transmit, and protect from disclosure all biometric information using a reasonable standard of care within Coinsource’s industry, and in the same manner in which Coinsource stores, transmits, and protects other confidential and sensitive information.
3.6. Coinsource will permanently destroy biometric information no later than three (3) years after an individual’s last transaction with Coinsource.
4.1. Coinsource will obtain customer consent prior to collecting a customer’s biometric information.
4.2. Coinsource will use a customer’s biometric information to confirm the customer’s identity.
4.3. Coinsource will store and protect customer biometric information using the same standard of care and security it uses to protect other confidential and sensitive information.
4.4. Coinsource will routinely check its customer base on a biennial basis and permanently destroy all biometric information for customers that have not completed a transaction within that time.