BitOasis Bahrain W.L.L. (“BitOasis”, “we”, “our”, “us”), a company incorporated in Bahrain with company/license number 170759-1 and with its registered office at Flat No: 302, Building 551 Road No 4612, Block No 346 , Area: MANAMA / SEA FRONT owns and operates bitoasisbh.net, a website, our APIs, and mobile applications where users can buy and sell digital assets (“Platform”). You are expected to read this Privacy Policy (“Policy”) carefully as this Policy applies to your personal data, the information we collect, use, store, disclose or otherwise process personal data from you via the Platform and what happens to that information and any dispute over privacy. If we make any material changes to our privacy practices, we will post a revised Privacy Policy on this page, or we may contact you.

All capitalized terms are defined within the meaning of the Personal Data Protection Law No 30 of 2018 and its implementing regulations (“Privacy Laws”). The term “Data or Personal Data” shall mean any information in any form concerning an identified individual, or an individual who can, directly or indirectly, be identified by reference, in particular, to his or her personal identification number, or by reference to one or more factors specific to his or her physical, physiological, intellectual, cultural, economic, or social identity. In determining whether an individual is identifiable, all the means that the data controller or any other person uses or may have access to should be taken into consideration.

Sensitive Personal Data shall mean any personal information revealing -directly or indirectly- about an individual's race, ethnic origin, political or philosophical opinions, religious beliefs, affiliation to union, personal criminal record, or any information in relation to his health or sexual status.

The term “processing” shall mean and include any operation or set of operations which is performed upon personal data, whether or not by automatic means, including collecting, recording, organizing, classifying into groups, storing, adapting, altering, retrieving, using, disclosing by transmission, dissemination, transference or otherwise making available for others, or combining, blocking, erasing or destructing such data.

1. Information We Collect and How We Collect It
   1. We may collect, store, use, disclose and process the following data about you:
      1. Information You give us - You may be required to give us your Personal Data (including Sensitive Personal Data) while creating a User Account, or during your continued use of our Platform. You hereby agree to provide us with the accurate information, and ensure that you keep the same updated as and when the need arises. We receive the following information directly from you, thereby enabling you to make use of our Platform:-
         1. Identification details: name, nationality, gender, marital status, age/date of birth, name of partner and children(s), passport number, national identity, utility bills for proof of address, photograph etc which are used for the purposes of registering your valid profile with the Platform.
         2. Correspondence information: includes information such as billing address, delivery address, email address and telephone number(s).
         3. Transactional information: transactional information by using the Platform and meta data based on your use of our Platform such as orders, trades, fiat currency account balances, Digital Currency account balances, transaction history, correspondence submitted by you to us and other content that you generate that relates to your account.
         4. Financial Data - Bank Account Details, permanent account number, credit or debit card number, transaction history, trading data, UPI, tax identification details, Digital Assets information including but not limited to any wallet address or details, which are used for the purposes of enabling and effecting transactions on the Online Platforms.
         5. Location Data - we may seek your location data for providing certain Services or in order to enable you to access certain features of the Online Platforms or in the event we suspect any fraudulent transactions.
         6. Any other information which you may provide to us when you leave us a message, during customer-support conversations, surveys, or for assistance in case of matters related to law enforcement, investigations.
   2. We may also collect certain personal identifiers from you automatically, during your association with us:
      1. Technical information: IMEI or equipment identification numbers, IMSI or subscriber identification, UUID, MAC address, OS version, device details, network operator, Wi-fi/data network connectivity, etc. Internet protocol (IP) address, your login information, browser details, time zone setting, browser plug-in types and versions, operating system and platform and other similar information.
      2. Access to your apps and services including messaging through SMS; Storage data, device details.
      3. Information about your visit: Uniform Resource Locators (URL) clickstream with timestamp; transactions and trades executed or attempted to be executed by you; viewed and searched items; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
      4. Information relating to fund transfer requests executed by you while accessing Services through our Online Platforms. In such transactions, we may collect information relating to such transactions provided by you or by a Selected Third Party.
      5. Metadata is usually technical data associated with the content you submit, post or share on the Website. Users can add or may have metadata added to their content including geolocation, date, attribution, or other data.
      6. Our Online Platforms use cookies and tracking technology (including pixels) depending on the features offered. This also allows us to improve the Platforms and our Services. Third parties may also use such cookies and tracking technology if you interact with any content provided by them through our Platforms, however we endeavour to identify these cookies before they are used and afford the choice for you to accept or deny them. The information discussed here is processed for the purposes of ensuring that the Services brought to you are in order and enable us to continuously monitor and update our Platforms, Services.
2. Information We Receive from Third Parties - We may receive information about you from third parties if you have volunteered/ consented for such information to be shared with us. We may combine and process such data internally towards our Services. We also work closely with select third parties (including, for example, subcontractors such as advertising networks, analytics providers, search information providers, infrastructural services, including cloud service providers) and may receive information about you from such sources. We may also collect and receive information in an aggregated form from different browser types for analysis.
3. How We treat your information
   1. By providing consent under this Policy, you grant us the permission to collect, use, copy, transmit, process, disclose, store and back-up your Personal Data and/or Sensitive Personal Data for purposes of the Services and/or for any other purpose mentioned below. We shall not be responsible for the authenticity of the personal identification information, Personal Data, Sensitive Personal Data or any other information supplied by you to us or any other person acting on our behalf. We use your information:
      1. to create and register your User Account with us, and maintain your records and profile details, and authenticate such information;
      2. to inform you of promotions, offers, surveys, events, products and services, which may be of interest to you;
      3. to facilitate and provide the services offered through the Online Platforms;
      4. to carry out our obligations arising from any contracts entered into between the Company and you;
      5. to enhance the security of our Online Platforms;
      6. to personalize content/Services offered to you;
      7. to facilitate transactions related to digital assets;
      8. to provide you, or permit selected third parties to provide you;
      9. for KYC verification of the details of Tax Identification Details and other Identification documents provided by you. We may seek you to validate such information by way of OTP, or by having a third-party service provider to authenticate and validate such information, only with your consent hereunder
      10. to prevent and identify suspicious /other illegal transactions in order to mitigate risks relating to money laundering and other illegal activities, and discharge any other duties and obligations to meet the legal and regulation requirements under the applicable laws.
   2. We may transfer your Personal Data if we are acquired by or merged with another company. In such an event, we will notify you and take your prior consent before your Personal Data is transferred and becomes subject to a different privacy policy
4. Retention and Storage of Personal Data

   Notwithstanding anything contained herein or in the Terms, we retain any information and/or data provided by you, for as long as required for resolution of disputes, for the purpose of ongoing investigations or to fulfill the purposes for which the data was collected including for the purposes of satisfying any legal, accounting, or reporting requirements, as per CBB Laws and Regulations.

   We maintain reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete and current. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data. We will retain your personal data in accordance with this Policy.

   In general terms, this will mean that personal data will be kept for the duration of our relationship with the individual and the period required by tax, company and financial services laws and regulations. We are required to retain data for up to 10 years for the purposes of compliance with AML/CFT regulations. We may retain necessary Personal Data for up to 15 years from the termination of our relationship with you to exercise our legal rights in the event of a complaint or prospective litigation in respect to our relationship with you.

   When it is no longer necessary to retain your Personal Data, we will securely delete it, subject to applicable law and regulations;

   Except for retention periods as set out herein, we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

   If you request that we stop sending you marketing materials, we will continue to keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.

   If you make a data subject request, we will retain the minimum required amount of data in order to keep a record of your request and the action we took to resolve it.

   In certain circumstances, personal data may need to be retained for a longer period where extended retention periods are required by law and in order to establish, exercise or defend our legal rights.

5. YOUR RIGHTS
   1. You may deal with your personal data available with us in the following ways:
      1. to check whether we hold Personal Data about you and to access such data;
      2. to ask for a copy of the Personal Data we hold about you in a structured, commonly used and machine readable format (or, when this is possible, ask for such personal information to be communicated on your behalf to another data controller);
      3. to know how their data is being used, including who is collecting and where it has been shared;
      4. to require us to correct when communicated to us by you in writing, as soon as reasonably practicable any data relating to you that is inaccurate or deficient;
      5. to ascertain our policies and practices in relation to Personal Data held by us;
      6. to object to the use of your Personal Data where we do so for one of the following reasons (i) because it is in our legitimate interests to do so; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; or (iv) for scientific, historical, research, or statistical purposes. (v) if causing material or moral damage to you (vi) If a decision is based solely on automated processing of personal data, but processing of such requests is subjected to procedures issued by the data protection board;
      7. right to withdraw consent, where we have obtained your consent to process your Personal Data for certain activities; and
      8. to ask us to erase, block and forget your Personal Data. However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
      9. We will ensure to provide a fair resolution to all your queries however, if you feel the right has been violated, you may lodge a complaint with the Bahrain Personal Data Protection Authority (Bahrain PDPA).
6. CROSS BORDER TRANSFERS
   1. To facilitate our services through our global infrastructure, your Personal Data may be transferred to and stored in locations outside of the Middle East ("Alternate Country") by us or our Affiliates/Partners located in foreign jurisdictions. We will do this only when the transfer is lawful, and only when the same is required for us to meet our contractual and statutory obligations. For completeness, the Personal Data which may be transferred outside is such information which may be sent to foreign jurisdictions as per the applicable laws. You hereby confirm that you have noted the aforementioned provisions and accordingly consent to the same.
   2. When we transfer your Personal Data from Bahrain (country, state and city in which you are present) to the Alternate Country (another country, state and city), we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.
   3. Our lawful basis for such transfer will be either on the basis of consent or one of the safeguards permissible by the applicable laws. We also rely on decisions from the European Commission where they recognise that certain countries and territories outside of the European Economic Area ensure an adequate level of protection for personal information.
7. CHILDREN'S PERSONAL DATA

   Unless otherwise indicated, you are only allowed to use our Platforms and Services if you are over the age of 18 (eighteen) years. We do not knowingly collect Personal Data from individuals under 18 (eighteen) years of age, without the consent of the parents/legal guardians or unless the information is provided to use by the parents or legal guardian.

8. NON-PERSONAL INFORMATION COLLECTED BY US

   Non-personal data or information is information that does not personally identify you. When you visit and interact with our Platforms or third parties with whom we have contracted to provide services, non-personal information, like a list of website pages visited by you, domain name, areas of the site you visit, URL, etc. could be collected to enhance your online experience by understanding your web usage patterns.

   We may use or disclose non-personal information for any purpose from time to time, for instance, we may embed email addresses with images. In such cases where we combine non-personal information with personal information, the combined information will be treated by us as personal information as per this Policy.

9. Third Parties and Service Providers
   1. We may use a variety of third party service providers to help us provide our Services. We may transfer your personal data to service providers and agents appointed by us for the purpose including but not limited: (a) to authenticate your identification information and documents to process your payments; (b) to check information against public databases; (c) for fraud prevention and risk assessment; (d) to allow the provision of Services through third party platforms and software tools; (e) to provide customer service and for marketing, (f) to process and handle claims (g) to our professional advisors (e.g. auditors, lawyers, accountants, or public relations advisers) (h) to process data on our behalf as part of outsourcing arrangements including IT service providers and data storage providers.
   2. The third party service providers shall have limited access to your Personal Data for performance of the above tasks and in accordance with our strict directions and policies.
   3. We may transfer personal data about you to meet legal or regulatory requirements or while conducting our usual business to the following external recipients:
      1. To other third-party agencies and suppliers in order to carry out AML/CFT/KYC/PEP/Fraud checks and comply with legal obligations;
      2. To our subsidiaries, affiliates and other companies under DCX Group where it is required to facilitate our services to you.
      3. To third-party service providers who work on our behalf to maintain client accounts and custody providers.
      4. To public authorities such as tax authorities, supervisory authorities, regulatory authorities, and other government agencies, security, or police authorities as part of our regulatory reporting requirements;
      5. To third parties who have introduced you to us such as financial service providers, your agents, advisers, and intermediaries in order to process the personal data for the purposes as set out in this Policy.
10. Use of Cookies and Similar Technology
    1. We may track certain information about you based upon your behaviour on our Platforms or while accessing our Services. You agree that we may use such information to do internal research on our Users' demographics, interests, and behaviour to better understand, protect and serve our Users. This information is compiled and analysed on an aggregated basis.
    2. The Platform uses cookies to distinguish you from other Users of the Online Platforms. This helps us to provide you with a good experience when you browse the Online Platforms and also allows us to improve the Online Platforms. By continuing to browse the Online Platforms, you are agreeing to our use of cookies. Usage of a cookie is in no way linked to any personally identifiable information on our Online Platforms.
    3. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer and on your other device if you agree. Cookies contain information that is transferred to your computer's hard drive.
    4. Please note that third parties (including, for example, advertising networks and providers of external services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
    5. We may use certain third party web analytics services on the Online Platforms such as Google Analytics tools offered by Facebook and/or LinkedIn which may use technologies such as cookies, web server logs and web beacons to collect information and help us analyze how visitors use the Online Platforms. These analytic services may use the data collected to contextualize and personalize the marketing materials of their own advertising network.
    6. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of the Online Platforms or avail of our Services. You further agree that if you send us personal correspondence, such as emails or letters, or if other Users or Third Parties send us correspondence about your activities or postings on the Online Platforms, we may collect and/or store such information.
11. Data Protection

    We will: (a) comply with all applicable Laws and standards in relation thereto/to your Personal Data and ensure that no act/omission of ours causes a breach thereof; and (b) immediately report theft or loss of Personal Data.

    1. Any Personal Data collected or accessed by us shall be limited to that which is necessary to perform our obligations in relation to the Services offered on by us or to fulfill any legal requirements. We shall not share any Personal Data that is collected or possessed by us with any third party for any reason except as expressly stated in this Policy.
    2. You agree that other than as stated in this Policy, we shall have the right to collect and/or use or analyze the Personal Data on an anonymised basis and in no way shall the Personal Data be used in a way that can lead to or reveal your identity. We advise you not to include Sensitive Personal Data in any emails you may send to us. Please do not send credit/debit card numbers or any other Sensitive Personal Data to us via email.
12. Third Party Links

    Our Services and Platform may contain links to third party applications/websites. Please note that when you click on one of these links, you are entering another application/website over which we have no control and will bear no responsibility. We do not own or control these third party applications and when you interact with them you may be providing information directly to them or us or both. Often such a third party application/website will require you to enter your Personal Data, and use/collect your Personal Data, in accordance with its own privacy policy and standard practices. You are requested to exercise your own discretion in this regard and you agree that we shall not be liable for any breach of your privacy of Personal Data or loss incurred by your use of these applications/websites.

13. Changes to the Policy

    We may update this Policy from time to time when required by the applicable law or due to business reasons and provide you with notice of the same. We encourage you to periodically review the Policy for the latest information on Our privacy practices. Continued use of the Platforms constitutes agreement of the User to the terms contained herein and any amendments thereto.

14. Disputes and Legal Proceedings

    We regularly review our compliance with this Policy. If we receive a formal written complaint from you, we will attempt to contact you directly to address any of your concerns. We will cooperate with the appropriate governmental authorities to resolve any complaints regarding the collection, use, transfer or disclosure of information that cannot be amicably resolved between you and BitOasis. The Services are governed by the laws of the Kingdom of Bahrain. Any dispute, controversy or claim arising out of or relating to this Policy or the breach, termination or validity thereof shall be finally settled pursuant to the terms of the User Agreement.

15. Contact Us

    We may provide any notice to you under any of our policies by sending a message to the email address then associated with your User Account. Notices we provide by email will be effective when we send the email. It is your responsibility to keep your email address updated. To give us notice under any of our policies, you must contact us by email, overnight courier or registered mail to the mailing address listed below. Notices to us must be sent details to [email protected] or to any other email address notified by email to the User by us, or by electronic communication via the Online Platforms from time to time for such purpose.