Please read this Privacy Policy, which describes how PlasBit, Inc. (“PlasBit”, “we,” or “us”) gathers, uses, stores, shares and protects your personal information gathered when you download our software or use our websites, networks, applications or any of our other services (our “Service”). This Policy is incorporated into and is subject to our Terms of Service. You accept this Privacy Policy when you sign up for our Service.
About our privacy policy
We respect your right to privacy and take seriously our responsibilities in relation to the processing of personal data. We do not collect or process personal data unnecessarily. This privacy policy (the “Policy”) together with our terms of service (the “Terms of Service”) sets out important information about your rights in relation to the processing of your personal data, and the basis on which any personal data we collect from you, or that you provide to us, will be processed in connection with your use of this website ( “Site”) and/or the PlasBit platform, app or service (the “Services”).
Controller
Under this Policy, and unless the circumstances otherwise require, we will be what’s known under the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) as the “controller” of the personal data you provide to us. As data controller we determine the purposes and means of processing your personal data.
Information We Collect
Whether you register for the use of our Services or you are a visitor to our Site, we may collect and store the following information:
Information given by you
When you register to use the Service, we will collect “personal information” that specifically identifies you as an individual.
The information you give us may include:
- Identity Data: your full name, address, e-mail, phone number, personal identity document (ID, passport or other).
- Financial Data: your financial and credit card information, including bank account and payment card details, billing contact email address, and VAT number.
The information we collect about you
Automatically Collected Information. With regard to each of your visits to our Platform we will automatically collect the following information:
- Identity Data: your full name, address, e-mail, phone number, personal identity document (ID, passport or other).
- Financial Data: your financial and credit card information, including bank account and payment card details, billing contact email address, and VAT number.
- Integrated Services Data: You may be given the option to access or register for the Service through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”) or otherwise have the option to authorize an Integrated Service to provide personal information or other information to us.By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.
- Technical Data: information such as your IP address or other device address or ID, web browser and/or device type, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service. We also may collect information regarding the interaction of the Service with printers, such as whether you printed, paused or canceled a design.
- Usage Data: information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through, and from our site (including date and time), products you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us
- Information from Other Sources: We may obtain information, including personal information, from third parties sources, such as third party websites services that make products available to You.
- Public Data: publicly available data to create a more complete customer profile and provide better customer support. “Public Data” is defined as the made legally available in the public domain.
No special categories of personal data: We do not require or collect any personal data that is your sensitive personal data or any special category of personal data under the GDPR unless you decide to provide this information to us.
What we do with your information
We will only process your personal information in accordance with the GDPR. Most commonly, we will use your personal data in the following circumstances:
- When we need to identify and verify your identity to comply with our AML obligations
- Where we need to provide our Services to you.
- Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with other regulatory obligations.
We have set out below, in a table format, a description of the ways we plan to process your personal data and the legal basis we rely only on to do so. We have also identified our legitimate interests where appropriate:
| Purpose/Activity | Type of data | Legal basis for processing |
|---|---|---|
| To verify your identity and assess the level of money laundering risk | Identity Data | Performance of a legal obligation |
| To set up and administer your account for the Services | Identity Data, Financial Data | Performance of a contract with you |
| To provide the Services and perform our obligations arising from any contracts entered into between you and us | Identity Data, Financial Data, Technical Data, Usage Data | Performance of a contract with you |
| To manage payments, fees, and charges and to collect and recover money owed to us | Identity Data, Financial Data | Performance of a contract with you, Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you, including notifying you about changes to the Services, our Terms of Services or Privacy Policy | Identity Data, Technical Data, Usage Data, Public Data | Performance of a contract Necessary to comply with a legal obligation necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services) |
| To provide you with information about goods and services we offer that are similar to those that you have already purchased or enquired about | Identity Data, Technical Data, Usage Data, Public Data | Necessary for our legitimate interests (to develop our products or Services and grow our business) |
| Where you have given us your consent to do so, to provide you with information about other goods or services we feel may interest you | Identity Data, Technical Data, Usage Data | Consent |
| To ensure that content is presented in the most effective manner for you and for your computer or device | Identity Data, Technical Data, Usage Data | Necessary for our legitimate interests (to keep our Site and the Services updated and relevant and to develop and grow our business) |
| To administer and protect our business, our Site, the Services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes | Identity Data, Technical Data, Usage Data, Public Data | Necessary for our legitimate interests (for running our business and as part of our efforts to keep our Site and the Services safe and secure) |
| To use data analytics to improve or optimize our Site, Services, marketing, customer relationships, and experiences | Technical Data, Usage Data | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site and the Services updated and relevant, to develop and grow our business and inform our marketing strategy) |
| To measure or understand the effectiveness of advertising we serve to you and others, and, where applicable, to deliver relevant advertising to you | Identity Data, Technical Data, Usage Data | Necessary for our legitimate interests (to study how customers use our products or Services, to develop them, to grow our business, and to inform our marketing strategy) |
Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@plasbit.com If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with this Policy, where this is required or permitted by law.
How long we keep your information
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This means that the period of time for which we store your personal data may depend on the type of data we hold. 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 unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
How we disclose collected data
On a case by case basis, we can disclose the collected personal data, exclusively for processing purposes to:
- the companies that are part of the PlasBit group
- our service suppliers (acting as processors or as persons empowered by us) and which we contract for the administrative and processing services of our transactions, for marketing, other services suppliers (e.g., suppliers of payment services, courier companies, suppliers of IT services)
- other companies and enterprises with whom we can develop joint programs of offers on the market of our products and services
- public authorities, if the disclosure is necessary in order to comply with an obligation provided for by the applicable legislation
The transmission of the collected personal data to the above-mentioned recipients will be done only based on a confidentiality commitment and a commitment to ensure the adequate level of security by such recipients, guaranteeing that the personal data is kept safe, and its transmission is carried out in accordance with the legislation in force.
We use the services of Sum and Substance Ltd (UK), Company Registration Number: 09688671, which is registered with the Information Commissioner’s Office in line with the Data Protection Act 2018, and Onfido, Company Registration Number: 07479524, to verify your identity and address and to assess the level of money laundering risk. We also use Transak for ON/OFF Ramp services. For more information on how these service providers process your personal data, please visit Sumsub.com, Onfido.com, Transak.com.
We use Amazon Web Services (“AWS”) as a cloud provider to store the data collected from you. For more information on how AWS as a service provider process personal data, please visit AWS.
Your Personal Data and Your Rights
Accessing your Personal Data
You may request access at any time to a copy of the personal data we hold about you. Any such request should be submitted to us in writing and sent to support@plasbit.com. We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested. There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive, or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
Right of Restriction
You may restrict us from processing your personal data in any of the following circumstances:
- You have contested the accuracy of the personal data we hold on record in relation to you or for a period of time to enable us to verify the accuracy of the personal data
- The processing of your personal data is unlawful and you request the restriction of the use of personal data instead of its erasure
- We no longer require your personal data for the purpose of processing but you require this data for the establishment, exercise, or defense of legal claims
- Where you have contested the processing (under Article 21(1) of the GDPR) pending the verification of our legitimate grounds
Corrections or Erasure (Right to Rectification and Right to Be Forgotten)
If we hold personal data concerning you which are no longer necessary for the purposes for which they were collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at support@plasbit.com.
Your Right to Object
You have the right to object to the processing of your personal data at any time:
- For direct marketing purposes
- For profiling, to the extent it relates to direct marketing
- Where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights, and freedoms or in connection with the enforcement or defense of a legal claim
To exercise your right to object at any time, please email support@plasbit.com. Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. For more information about our marketing practices, please see the Marketing Communications section below.
Data Portability
Where we process your personal data by automated means (i.e., not on paper) and this processing is based on your consent or required for the performance of a contract between us, you have the right to request from us a copy of your personal data in a structured, commonly used machine-readable format and, where technically feasible, to request that we transmit your personal data in this format to another controller.
Changes to this Privacy Policy
If we make any material changes in the way we use your personal information we will notify you by posting a prominent announcement on our website at least fifteen (15) days prior to the change taking effect. Any revised Privacy Policy will only apply prospectively to personal information and/or non-personal information collected or modified after the revised policy's effective date. You should periodically review the Privacy Policy available on our website for revisions. Use of our Service and/or our website after revision of the Privacy Policy signifies your consent to the revised Privacy Policy.
Information Access/Questions About Your Privacy
If you have any questions or concerns regarding this policy, or you wish to access a copy of the data we hold about you, please contact support@plasbit.com. Also, use that email address to request a correction, amendment, or deletion of the information we hold about you if it is inaccurate or has been processed in violation of the Principles. We will endeavor to comply with every request made via this channel, except where the burden or expense of providing access would be disproportionate to the risks to Your privacy or where the rights of persons other than You would be violated.