Privacy Policy

Last Updated: January 1, 2022

Ky0x, powered by Springcoin, Inc. d/b/a/ Spring Labs, (the “Company”) respects the privacy of the users (each, “you” or “User”) and is committed to protect the privacy of Users who access, download, install or register to our ky0x website, platform, applications, or any online or related services we provide (collectively, the “Services”). This privacy policy (the “Privacy Policy”) does not apply to Company websites that post different statements. The Company has published this Privacy Policy to outline our practices with respect to collecting, using, and disclosing your information when you use the Services.  We encourage you to read the Privacy Policy carefully and to use it to make informed decisions.  By using the Services, you acknowledge you have read and understand the terms of the Privacy Policy and your continued use of the Services constitutes your ongoing acknowledgement thereof.  The Privacy Policy is applicable for the data processing activities carried out in relation to the provision of the Services in accordance with the Terms of Service.

 This Policy applies to information you provide to us or that we collect through the Services.  By accessing or using the Services, you acknowledge the collection, use, disclosure and processing of your personal information (including personal data, hereafter “Personal Information”) by the Company acting as data controller, as set forth in this Policy.  Prior to submitting any information on or through our Services, please carefully review this Policy. This Policy applies only to information you provide to us, or we collect through the Services and if the Services are accessed or connected through other third-party service providers and any related third-party applications, this Policy only covers the information that the Company collects, uses, shares in connection with the Services. 

 We will evaluate this Policy and may update this Policy periodically, in which case we will inform you thereof.

What We Collect

We get information about you in a range of ways.

  • Information You Give Us. We may collect your first name, last name, address, email address, wallet address, date of birth, government identification documents (ex: driver’s license number or passport information) as well as other information and identifiers as you provide to us on through application or performance of the Services.  All information we collect from you through or in connection with the Services are covered by this Policy. 
  • Information We Get From Others. We may get identifiers and other information about you, from other sources.  We may add this to information we get in connection with performing the Services.
  • Information Automatically Collected. Like many companies, we automatically log information about you and your computer. For example, when visiting and accessing our Services, we log your computer operating system type, browser type, browser language, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site and use of our Services.
  • Cookies. The Company has a separate Cookie Policy accessible on the Site. Please review our Cookie Policy for more information about how we use cookies and your options related to cookies.

Use of Personal Information

We use your personal information as follows:

  • To set up your account and to provide the Services, including performing the related Know-Your-Customer and Anti-Money Laundering verifications.
  • To improve and enhance our Services and functionality of the Services.
  • To send information including confirmations, technical notices, updates, security alerts, and support and administrative messages.
  • To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
  • To maintain legal and regulatory compliance.
  • To investigate violations and enforce our policies, and as required by law, regulation, or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request
  • To generate anonymous de-identified and/or aggregated data that we may use for any lawful purpose.
  • To perform research or conduct analytics in order to improve and customize the Services to your needs and interest, including to undertake internal research and reporting.
  • To enable us to develop and/or reorganize our business activities in relation to any corporate transactions or negotiations, including with potential purchasers or investors in the company, financing, or bankruptcy transaction or proceedings.

Sharing of Personal Information

We may share personal information as follows:

We do not rent, sell, or share your Personal Information with third-parties except as described in this Privacy Policy.  In addition to our duly authorized personnel, we may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) subcontractors, vendors, or other third-party service providers; and (iv) auditors or advisers of our business processes.

We may also disclose Personal Information or any information you submitted via the Services if we have a good faith belief that disclosure of some information is helpful or reasonably necessary to: (i) comply with applicable laws, regulations, legal processes or governmental requests; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property, or safety of us, our affiliates, our Users, yourself or any third-party; (vi) for the purposes of collaborating with enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

Information Choices and Changes

Any marketing emails we may send will tell you how to “opt-out” from further communications. If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about our business dealings with you and in connection with the Services. You are permitted to decline to share certain Personal Information with us; however, in such case, we may not be able to provide to you some, if not all functionality of the Services. 

 You may send requests about Personal Information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your Personal Information. When you update or request a change to certain information, we may maintain a copy of the unrevised information for legal and compliance purposes. 

You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Services work for you.

Children’s Privacy. Our Services are not intended for use by children. We do not knowingly collect Personal Information from children under the age of 18 years. Please contact us if you believe we may have unknowingly collected information about a child under 18.

Rights of Residents of the EU

This section applies to those that visit our Site or use our services from the European Economic Area (EEA) or Switzerland.

If you are a resident of the European Union, please note that the following rights specifically apply regarding your Personal Information: (1) Receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with supplementary information; (2) Receive a copy of Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format; (3) Request rectification of your Personal Information that is in our control; (4) Request erasure of your Personal Information; (5) Object to the processing of Personal Information by us; (6) Request to restrict processing of your Personal Information by us; (7) Withdraw your consent for data processing activities that rely on your consent as a legal basis, and (8) Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements and/or conditions.

To exercise such rights, you may contact us at: info@ky0x.com

In addition, please note VeraSafe has been appointed as Company’s representative in the  European Union for data protection matters, pursuant to Article 27 of the General Data  Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to Company  only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031. 

Alternatively, VeraSafe can be contacted at: 

VeraSafe Ireland Ltd. 
Unit 3D North Point House 
North Point Business Park 
New Mallow Road 
Cork T23AT2P 
Ireland

Lawful Basis of Processing

Depending on the purposes of the relevant processing activity, the processing of your Personal Information is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests or to comply with our legal obligations. To the extent that processing is based on consent, you have the right to withdraw consent.

 In particular:

  • processing your Personal Information for providing the Services and sending the related communications is necessary for the performance or our contractual agreement with you;
  • processing your Personal Information for improving and enhancing our Services is based on our legitimate interest for improving and further developing our Services;
  • processing your Personal Information to send you commercial communications is based on our legitimate interest to further develop the relationship with you, unless you have provided consent for receiving such communications;
  • processing your Personal Information for statistical, research or analytics purposes is based on our legitimate interest to better understand your interaction with and use of our Services;
  • processing your Personal Information in relation to negotiations or potential transactions required for reorganizing our business is based on our legitimate interest to further develop our business activities;
  • processing your Personal Information for responding to requests from regulators, administrative or judicial authorities is required for compliance with our legal obligations.

Protection of Your Information

 We take great care in implementing and maintaining the security of the Service and your information.  We employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise that we will prevent such access. If you feel that your privacy was not treated in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at info@ky0x.com.

Transfers of Personal Information

Please be aware that the Personal Information we collect may be transferred to and maintained on  servers or databases located outside your state, province, country, or other jurisdiction, where the  privacy laws may not be as protective as those in your location. Please be advised that we process and store Personal Information in the United States and you acknowledge such processing. To the extent your Personal Information is transferred by the Company to recipients located outside of the EEA or a country for which an adequacy decision has been issued by the European Commission, the Company will implement appropriate safeguard mechanisms such as standard contractual clauses.

Retention

We may process and store your Personal Information only for the period necessary to achieve the  purpose of the storage, or as permitted by law. We may retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of a contract or the initiation of a contract or for other lawful purposes.

In particular:

  • when processing your Personal Information for providing the Services, we retain your Personal Information for seven years;
  • when processing your Personal Information for improving and enhancing our Services, we retain your Personal Information for seven years;
  • when processing your Personal information to send you commercial communications, we retain your Personal Information for three years as from your latest interaction with us, unless you have provided consent to receiving such communications, in which case we will retain your Personal Information until you withdraw your consent.

 Contact Information.

We welcome your comments or questions about this privacy policy. You may also contact us at our address:

Springcoin, Inc. 
4551 Glencoe Avenue, Suite 155
Marina Del Rey, CA 90292

Or via email at: info@ky0x.com

Changes to This Policy. We may change this privacy policy. If we make any changes, we will change the Last Updated date above.