Privacy Policy

1. GENERAL PROVISIONS

DOT BIG FINTECH LLC, EIN number: 87-1427721, registered office: 326 36 TH ST NE Cedar Rapids, IA, 52402 (“the Company”; “we”; “our”) and its affiliates respect your privacy, value its importance, and are fully committed to protecting and keeping your personal information secure.

This Privacy Policy together with our Customer Agreement governs collection, processing, and use of your Personal Information by the Company and applies whenever you visit or use our website or any other online services we provide (the “Services”).

We process your information duly and legally under the US data protection laws (“Regulations”) and other subsequent laws (“Data Protection Laws”).

It is important that you read this Policy along with any other privacy notices we may send when we collect or process your Personal Information, so that you are fully aware of how and why we use your information.

The policy applies to the following:

  • Your personal information we collect;

  • How we collect your information;

  • How we use your personal information;

  • Information retention;

  • Disclosure of your personal information;

  • International transfers;

  • Information security;

  • User rights;

  • Minors;

  • Changes to the Privacy Policy and your responsibility to inform us of any changes;

  • Our contacts.


2. YOUR PERSONAL INFORMATION WE COLLECT

We may collect, use, store, and transfer various types of your Personal Information in the following way:

  • A. Identification Data: first name, middle and last name, date of birth, nationality, passport/ID card/driver’s license number, username or similar identifier, marital status, job title, date of birth, gender.

  • B. Contact information: address (country, state, city, street, building number, apartment number), email address, telephone numbers.

  • C. Transaction data: debit/credit card details, crypto wallet details, your transaction history on the Company’s Platform, payments received and sent.

  • D. AML and KYC information: (i) a copy of your national ID, a passport and/or a driver’s license, (ii) a proof of residence address (for example, a recent utility bill, internet/cable TV/telephone line bills, bank statement, tax returns, municipal council tax invoices, certificates of residency issued  by the government), (iii) a selfie with the passport/ID card/driver’s license (for identity verification), (iv) KYC database checks, (v) fraud database checks, and (vi) any documents or information that any competent authority may authorize us to collect from time to time, including, as the circumstances require, any other documents or information that you may provide us with from time to time:

(a) is required to be collected to ensure compliance with any applicable laws (including applicable foreign laws) and international AML/KYC practices; and/or

(b) otherwise authorized to collect by the Financial Intelligence Unit (FIU) and/or any other competent authority, including, as the circumstances require, any other documents or information that you may provide us with from time to time in compliance with applicable law and any other competent authority or applicable law (including foreign authorities and applicable foreign laws).

  • E. Technical information: IP address, your login information, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technologies that you (as a Client or not) use on the devices to access and browse the Website, logs (all user activities on the Website).

  • F. Marketing and communication information: includes your preferences for receiving marketing from us or our third parties and your communication preferences. This may include your subscription to or unsubscribing from any of our mail-outs, attendance to any of our events, or acceptance of any of our invitations.

3. We will also collect, use, and process any other information that you voluntarily provide us with or disclose to us.

If you do not provide your Personal Information, we will not be able to execute or conclude the contract that we conclude or attempt to conclude with you (including with respect to opening your account and providing the Company’s services).

In certain cases, especially regarding particularly sensitive and important KYC information, we may have to exercise our prerogative to terminate our contract with you or refuse to enter into a customer relation with you.

In such cases, we will notify you in advance.


4. HOW WE COLLECT YOUR INFORMATION

Generally, we use various methods to collect your personal information, including by:

  • A. Directly interacting with you. You agree to provide us with your personal information by filling in the forms on our website, performing the required steps to apply, requesting and receiving our Services.

  • B. Automated technology or interaction. When you interact with our website, we may automatically collect technical information about your equipment, activities and browsing patterns. We may use cookies, server logs, and other similar technologies to collect this Personal Information. Please see our Cookie Policy for more information.

  • C. Third parties or publicly available sources. We may receive your Personal Information from various third parties (for example, third-party KYC providers) and publicly available sources.

5. HOW WE USE YOUR PERSONAL INFORMATION

We are careful about how we use your Personal Information. We will only use your Personal Information when permitted by law. Mostly, we will use your Personal Information when:

  • you want and agree to enter into a customer relation with us;

  • we need to execute a contract that we have or are about to conclude with you as a client;

  • it is necessary for our legitimate interests (or those of a third party) and when your interests and underlying rights do not contradict these interests;

  • we must comply with legal or regulatory obligations.



6. Please note that we may process your Personal Information incompliance with several legitimate grounds or reasons, depending on a particular purpose, which we use your information for.

We collect, use, and share your information for the following purposes:

  • to configure your account and providing the Services;

  • to identify and authenticate your access to particular functions of the Services;

  • to confirm your identity to comply with KYC regulatory requirements;

  • to communicate with you, provide you with the Services, and keep you informed about our latest updates;

  • to promote our Website and Services;

  • to conduct research or analysis to improve and customize the Services to meet your needs and interests;

  • to support and troubleshoot the Services, provide answers to your requests;

  • to investigate and resolve disputes related to your use of the Services;

  • to detect and prevent fraudulent, illegal activity or any other activity that may threaten or have a negative effect on the Service integrity;

  • to investigate violations and enforce compliance with our policies, as well as in compliance with the law, regulations, or other governmental authorities’ requirements, to comply with a request for summons or similar trial or to respond to a government request.

7. We will use your Personal Information in compliance with the Privacy Policy and will only use this information to the extent necessary for the purposes of using the Website, providing the Services, and informing the Website users about our Services.

8. INFORMATION RETENTION

We will retain your Personal Information only as long as it is necessary to fulfill the purposes for which we collected it and after that:

  • to comply with any legal, accounting, tax, anti-money laundering, and regulatory obligations, reporting requirements, which we may be subject to; and/or

  • to the extent that we may also need to retain your Personal Information to be able to assert, apply, or defend possible future legal complaints against you or otherwise related to you.

9. If you have not used your account for two (2) years and there are no funds in it, we will consider the account expired and your Personal Information may be deleted.

The Company can and will retain your information for six (6) years from the date of termination of your relations with the Company clients (which usually results from closing the company or closing your customer account). This retention period makes it possible for us to use your Personal Information for any applicable retention and reporting obligations regarding the KYC policy, as well as to file, enforce, or defend possible future lawsuits. In some cases, to comply with applicable accounting and tax laws (these will primarily be your Transaction Information), we may need to retain your Personal Information for up to ten (10) years. There may also be cases that require longer retention of your Personal Information, as required by the nature of the products and services provided.


10. DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose your Personal Information to the following recipients, which may be located in or outside your jurisdiction: (i) our subsidiaries; (ii) affiliated entities; (iii) subcontractors and other third-party service providers; (iv) our auditors or business process consultants; and (v) any possible purchasers or investors in the Company.

We may disclose your Personal Information to law enforcement, government, and judicial authorities (domestic and foreign).

We require that all our affiliates and third-party service providers respect your Personal Information security and treat it in compliance with the law. We do not allow them to use your Personal Information for their purposes and allow them to process your Personal Information only for the specified purposes and in compliance with our documented instructions.


11. INFORMATION SECURITY

We have taken appropriate security measures to prevent any accidental loss, use, or access to your Personal Information, or its unauthorized alteration or disclosure.

We also provide access to your Personal Information only to those employees, agents, contractors, and third parties who have the professional “need to know”. They will process your Personal Information only in accordance with our guidelines, and they will be subject to a confidentiality duty. All of our employees have completed appropriate data protection training.

We have implemented procedures to address any suspected Personal Information breach and will notify you and any applicable regulator of the breach if we are legally obliged to do so.


12. USER RIGHTS

Under data protection laws, you have the following rights related to your Personal Information:

  • request access to your Personal Information;

  • request to correct your Personal Information;

  • object to processing of your Personal Information;

  • request restriction of processing of your Personal Information;

  • request to transfer your Personal Information;

  • revoke your consent.

13. If you wish to exercise any of the above-listed rights, contact us at info@dot-big-fintech.com. It is generally free of charge. You will not have to pay any fees to access your Personal Information (or to exercise any other rights). However, we may charge a reasonable fee if your request is obviously unreasonable, repetitive, or excessive.

You have the right to file a complaint with the competent data protection supervision agency at any time, such as (in particular) a supervision agency at your place of residence or at the job address.

However, we would appreciate the opportunity to deal with your concerns before you contact a supervision agency, so please first contact us at info@dot-big-fintech.com.


14. MINORS

The Services are not intended for persons under 18 years of age. If you are under 18, you shall not use the Services or provide us with any Personal Information.

We reserve the right to access and check any Personal Information we receive from you. If we find out that any person under 18 has provided any information, we will reject such information. If you have any reason to suppose that a minor has shared any information with us, please contact us at info@dot-big-fintech.com.


15. CHANGES TO THE PRIVACY POLICY AND YOUR RESPONSIBILITY TO INFORM US OF ANY CHANGES

We may revise this Privacy Policy from time to time at our sole discretion. The latest version will always be available on our website. In case of any significant changes to the Privacy Policy, we may notify you via the Services or by email. We recommend that you should regularly check this Privacy Policy for any changes.

It is absolutely imperative that the Personal Information we retain is always accurate and relevant. Otherwise, it will impair our ability to provide you with the Services you may request from us.

Please keep us informed if any of your Personal Information changes during our relations with you.

 


16. OUR CONTACT INFORMATION

  • Full name of the legal entity: DOT BIG FINTECH LLC

  • Email address: info@dot-big-fintech.com

  • Mailing address: 326 36 TH ST NE Cedar Rapids, IA, 52402


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