BitWine

Last updated: June 20, 2020

Privacy Policy

Barges Technologies, Inc. (“BitWine”) respects our users’ privacy. The following is our privacy policy.

BitWine has created this privacy policy (“Policy”) in order to disclose our information gathering and dissemination practices for the different functions available by and through the Site and/or Services. This Policy applies to you if you are a user, Advisor or other visitor to the Site or Services made available at BitWine.com and at other third party websites. Users, Advisors and all other visitors to the Site and/or Services are referred to in this policy as “you”. BitWine will not disclose to third parties any personal information obtained from you, except as described or as provided for in the Terms of Service. Any terms not defined herein shall have the definition set forth in the Terms of Service.

This privacy policy has been updated to comply with the EU’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act of 2018 (CCPA).

By using BitWine’s Site and/or Services, you agree to this Policy. If you do not accept this Policy, you must not use the Site and/or Services.

Personal Information

You may browse the Site and/or Services without providing any personal information. However, the actual use of the Site and/or Services requires registration. When you register you will be asked to give us contact information, such as your name and email address. In addition, in the course of using our Site or Services, you may provide us with other personal information. Your personal information will be used primarily in connection with operating and facilitating the services provided by and through the Site and the Services, including contacting you so that we may provide the service you have requested or respond to your requests for information or customer service. This information may also be used to send you updates regarding our company or to share with you other services or benefits that may be of interest to you.

We do not collect or have access to any user financial information, even though we may request information about yourself and your credit card and/or bank account. That financial information is handled, processed, and stored by a third party payment service (such as PayPal or another third party), which facilitates credit card payments in order to purchase a product through the Site. Currently, the Site and Services use PayPal as its third party payment service, but BitWine may, in its sole discretion, choose another third party payment service for the Site and Services. PayPal takes the privacy of your personal information seriously and will use your information only in accordance with the terms of their privacy policies, available at https://www.paypal.com/us/webapps/mpp/ua/privacy-full

The following is a list of personal information collected by BitWine:

  • Email address
  • Login name
  • Full name
  • PayPal payer ID
  • PayPal email address
  • IP address
  • Geographic location
  • Profile photo
  • Chat transcripts
  • BitWine messages
  • Favorite advisors list
  • Reviews
  • Forum posts and replies
  • Information in your customer service inquiries

This information will be stored on third party partner servers (e.g. Amazon Web Services) for as long as your account is active. User data is hosted on servers belonging to third parties with whom we have signed Data Processing Agreements. All third party partners are GDPR-compliant. All communications on BitWine are stored, and are used for analytics purposes, for quality assurance, and to maintain long-term relationships between clients and advisors.

Rights under GDPR

Under certain circumstances, users based in the EU have rights under data protection laws in relation to your personal data, namely:

  • Access, correction, update, or erasure of your data: You may have the right to request access, correction, update, or erasure in regards to any personal data we hold about you. We will consider your request in accordance with applicable laws.
  • Restriction of processing your personal data. You may have the right to prevent or restrict processing of your personal data.
  • Portability of your personal data. You may have the right to request transfer of your personal data to a third party, when technically feasible.

You can exercise any of these rights by contacting us.

Additional Information for California Residents

This section contains information about policies that apply solely to California residents who use Site and/or Services. If you are a California resident, as of January 2020 you have certain rights regarding your personal information under the California Consumer Privacy Act of 2018 (“CCPA”):

(1) Right to Know About Personal Information Collected, Disclosed, or Sold

You may request that we provide you with the following information:

  • The categories or specific pieces of personal information that we have collected about you.
  • The categories of sources from which the personal information was collected.
  • The purposes for collecting, using, or selling that personal information. Please note that we do not sell personal information (as we understand the term “sell” to be defined in the CCPA).
  • The categories of third parties with whom we shared that personal information.
  • The categories of personal information we have disclosed or sold for a business purpose.

Details about the personal information we collect can be found in the “Information Collection and Use” section of this Privacy Policy. The supplemental policy for the CCPA regarding the personal information we have collected over the last 12 months, including the categories of personal information, business purposes, and whether we collect or sell your personal information are provided below:

Categories of personal information Business purpose Collected? Sold?
  1. Identifiers, such as full name, login name/nickname, street address, unique personal identifier, online identifier, date of birth, device type, unique device ID, browser type, Internet Protocol (IP) address, email address, account ID number, social security number, driver’s license number, passport number, signature, or other similar identifiers.
  • To provide our products and services to you.
  • To personalize, develop, and improve our products and services.
  • To create, customize, maintain, and secure your account with us.
  • To process your purchases, transactions, and payments.
  • To prevent fraudulent transactions and fraudulent usage of our products and services.
  • To provide you with customer support.
YES NO
  1. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)), such as: social security number, address, telephone number, passport number, driver’s license or state identification card number, PayPal payer ID, PayPal email address, bank account number, credit/debit card number, or any other financial information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
Same as category A above YES NO
  1. Protected classification characteristics under California or federal law, including (but not limited to): age, race, color, citizenship, religion, marital status, sex/gender/gender identity, sexual orientation.
Same as category A above
(only the information provided by you voluntarily is collected)
YES NO
  1. Commercial information, such as products or services purchased or other purchasing or consuming histories or tendencies.
Same as category A above YES NO
  1. Biometric information
Not applicable NO NO
  1. Internet or other electronic network activity, such as app/website usage history and information regarding interaction with our apps, websites, or advertisements.
Same as category A above YES NO
  1. Geolocation data
Same as category A above YES NO
  1. Sensory data, such as photographs, video recordings, or voice recordings.
Same as category A above YES NO
  1. Professional or employment-related information
Same as category A above YES
(advisors only)
NO
  1. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
Not applicable NO NO
  1. Inferences drawn from other personal information, such as consumer preferences, characteristics, trends, and behavior.
Same as category A above YES NO

Sources of Your Personal Information

The personal information we collect is obtained from the following sources:

  • Directly from you. For example, from forms you complete in our app or website, advisor applications or the purchase of products.
  • Indirectly from you. For example, through your interactions on our apps or websites.
  • From third parties. For example, third party social networking providers, analytics services, advertising companies, and affiliates. If you do not want us to collect information from such third parties, you should review and adjust your privacy settings on those networks accordingly. To assist you in doing this, we have provided links to opt out of these third parties below:

- Google Analytics: Opt-out page
- Facebook (advertising and analytics): Ad settings
- Mixpanel (analytics): Contact BitWine Customer Support



(2) Right to Request Deletion of Personal Information

Subject to certain limitations, you may request that we delete the personal information that we have collected about you. Upon verification of your request, we will queue your request for processing and notify you. If your request is denied, we will reply explaining why.


(3) Right to Opt Out of the Sale of Personal Information

Your personal information is “sold” when it is shared with a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as defined in the CCPA. We do not sell your personal information.

If you would like to opt out of promotional email messages, you may do so by clicking the “Unsubscribe” link in any of the email messages you receive.

(4) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you for exercising your rights under the CCPA.

To exercise the “Right to Know” or the “Right to Request Deletion”, please email Customer Support. Before processing your request, we may ask to verify your identity or the identity of your authorized agent. Requests will be handled within the timeframes specified in the CCPA.

Other Information BitWine Collects

BitWine may collect certain information from visitors of the Site and/or Services, such as Internet addresses and other web log information (such as your web request, Internet Protocol (“IP”) address, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser). This information is logged for internal use by BitWine, including helping diagnose technical problems and to administer the Site and Services in a manner that allows us to constantly improve the quality of the services provided to you. We may also maintain a record of your IP address, to analyze the use of our online services on an aggregate basis. We may also elect to share such information with advertisers and other third parties. BitWine is the sole owner of information collected on the Site. We reserve the right to screen, copy, transmit and review all communications conducted by or through the Site. We may conduct these activities for technical support purposes and in order to enforce our policies and agreements. At our sole discretion, we may decide to conduct these activities at various times or not at all.

We also may use your information to accomplish the following: (i) perform research and analysis about your use of, or interest in, our products, services, content, products, services or content offered by others; (ii) communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, other companies or other third parties; (iii) develop and display content and advertising tailored to your interests on our site and other sites, including providing our advertisements to you when you visit other sites; and (iv) perform ad tracking and website or mobile application analytics.

Cookies

BitWine may use “cookies” to monitor visitors browsing our website. Cookies allow the server to store its own information about a user on the user’s own computer. They can be used to customize pages for you based on information you may have provided to our website. Cookies may help us better serve you with information tailored specifically for you and for your return visit to the Site. Cookies are a typical part of web browsing today. Many websites that require you to type a password prior to entering a website use a cookie to facilitate the action. Additionally, many sites that do not require passwords also collect and utilize cookies. You are free to decline our cookies if your browser permits, although doing so may interfere with your use of the Site and Services.

“Do Not Track” Disclosure

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Information Collected By Third Parties

Our website may contain links to other websites. Those websites may be governed by terms and conditions and may have privacy policies that differ from ours. BitWine is not responsible for the privacy practices or the content of these other websites. You should exercise your discretion in disclosing personal information to other users of our Site. We are not responsible for any use of this information by you or others to whom you disclose such information by means of our Site and/or Services. In addition, communications between Advisers and Clients may not be encrypted using standard web encryption technologies, and/or when using third party communication platforms (such as Skype software, services, and/or platform). Third parties may improperly intercept or access transmissions or private communications, and other users may abuse or misuse your information that they collect from the Site. Therefore, although we try to protect your privacy, we cannot promise, and you should not expect, that your personal information or private communications will always remain encrypted and private. By using the Site and/or Services, you agree to use all information collected in connection with the Site and/or Services for lawful purposes and only in connection with your permitted activities in connection with the Site and/or Services.

We use Google AdWords Remarketing to advertise the Site and Services across the Internet. AdWords remarketing will display relevant ads tailored to you based on what parts of the Site and Service you have viewed by placing a cookie on your machine. Google AdWords Remarketing allows BitWine to tailor its marketing to better suit your needs and only display ads that are relevant to you.

How to Opt Out of Remarketing and Advertising: If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google’s Ads Preferences Manager.

Security

The information you provide to us will be kept in our database. We will use reasonable means to protect the integrity and safety of the database. However, we cannot guarantee that the database will not be improperly accessed by third parties. BitWine relies on professional hosting solutions that use reasonable care in maintaining security measures to protect you and our systems against unauthorized access to, or alteration, disclosure, destruction or loss of personal data hosted on our system.

Password

Your password is the key to your account. Use unique numbers, letters, and special characters and do not disclose your BitWine password to anyone. If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify BitWine and change your password.

Correcting, Sharing & Updating Your Information

BitWine allows you to view the information you have provided after registration and to correct any inaccuracies or errors that may exist in the data, however it is solely your responsibility to do so. Should you engage in any communication using the Site and/or Services, you bear the sole responsibility as to the substance, character, and nature of the information you provide during any such use. In addition, if you do not wish to furnish any information, then you should not do so.

You understand that if you engage in any form of communication with an Advisor or any user using the chat, email, voice or other communication facilities, functions, or software provided by and through the Site and/or Services, you may voluntarily provide, or otherwise be asked to provide, certain personal information, including without limitation your name and other information requested by an Advisor or otherwise to enable you to participate in the Site and or Services. BitWine may provide areas and functionalities on the Site and Services enabling you to post information about yourself and others and communicate with others,including Advisors. BitWine cannot control who reads your posting or what other users may do with the information you voluntarily post, so BitWine encourages you to exercise discretion and caution with respect to your personal information. BitWine also strongly encourages you to exercise caution and to use reasonable judgment in providing any personal information, including financial information, to any Advisor, and BitWine will not be held responsible for the manner in which any Advisor uses such information.

BitWine may from time to time, maintain transcripts of any such chats, emails and other communications conducted between you and any Advisor or other user using Site and/or Services. In addition BitWine may from time to time, in compliance with applicable law, record and maintain recordings of voice communications between you and any Advisor or other user.

Our Disclosure of Your Information

Your personal information may be disclosed to BitWine affiliates. In addition, we may disclose your personal information to third parties and the performance of the related services, including to service providers who help with our business operations. In addition, we may provide certain information presented to us by Advisors to third parties with whom we do business, and by registering or using the Site as an Advisor you hereby consent to such use of your personal information. We may disclose your personal information to enforce our agreements and policies or respond to claims that information submitted or other content or submissions violates applicable laws or regulations, the rights of others, or to protect anyone’s rights, property, or safety. We also may disclose your information to respond to legal requirements or when we believe in good faith that the disclosure of information is necessary to prevent imminent harm or financial loss or to report suspected illegal activity. We may use our discretion to disclose your information under appropriate confidentiality conditions in connection with merger, acquisition or sale of asset or business activities involving our company or its affiliates. We may disclose non-personally identifying information (including, without limitation, aggregated information) as we believe is reasonable in connection with our business. This information will not identify individual users. Information collected through the Site may be stored and processed in any countries in which we or our service providers maintain facilities, including outside of the European Union. You therefore understand and consent that your information may be transferred outside of the country in which you reside.

Changes to the Policy

BitWine reserves the right to replace, modify or amend this Policy from time to time by posting the replaced, modified, or amended terms on the Site, so we recommend that you review this Policy from time to time. Your use of any Site and/orServices following any change to this Policy shall represent your consent to the new Policy to the fullest extent permitted by law.

General Data Protection Regulation (GDPR)

For purposes of the EU’s General Data Protection Regulation (GDPR), the data controller is Barges Technologies, Inc., with an office at 7 World Trade Center, 10th floor, New York, NY 10007 USA.

If you feel that your personal data has been processed in a way that does not meet the GDPR, you have the right to file a complaint with the relevant supervisory authority.

Children’s Privacy

To use BitWine you must be at least 18 years of age. If you are under 18 years of age, please do not use our Site or Services.

Notification in the event of a Data Breach

In the event of a data breach, we will notify the owners of BitWine accounts within 72 hours of the discovery of said breach.

Additional Information

In the event that all or substantially all of BitWine’s assets have been acquired, or in the event of any merger, bankruptcy or reorganization involving BitWine, all information about you and your use of our services will likely be included in the acquired or merged assets.

If you reside in the European Union or other jurisdictions with laws governing data collection, privacy, and/or use, please note that you are transferring your personal data to the United States to BitWine and that U.S. rules governing data collection, privacy, and/or use may be less restrictive. By providing your personal data to BitWine you consent to that transfer.

From time to time, BitWine may use Data for new, unanticipated uses not previously disclosed nor described in our Policy. If our information practices change regarding information previously collected, BitWine will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

If you wish to apply to be an Advisor on BitWine’s Advisor Program, you will be required to submit certain personal information, as required. Any information supplied by or on your behalf for purposes of becoming an Advisor may be maintained by BitWine as well as third party affiliates and other third parties. BitWine may have additional privacy terms that apply to Advisors.

If you have any questions or would like further information regarding this Policy, please contact us.