Privacy Policy

Privacy @ Bitlogix

Bitlogix Online Privacy Policy

Bitlogix is committed to protecting and respecting your privacy. For the purpose of the European General Data Protection Regulation (the “GDPR”) and this policy, we are the data controller.

When you visit the Bitlogix website, www.bitlogix.com (the “Website”), you may provide us with specific personal information about yourself and we will receive some general information regarding your use of the Website. This online privacy policy (the “Online Privacy Policy”) describes the types of information that we receive from you when you visit our Website, what we do with it, how we protect it, and how you can contact us if you have a question or concern about the information we hold about you. Your use of this Website is also subject to the Terms of Use available on the Website.

Information We Receive When You Visit Our Website and How We Use It

We collect the following information about visitors to the Website:

• You may choose to contact Bitlogix using the contact information form available on the website. In such instances, your name, email address, phone number, company name, address, and comments will be collected as part of the process of transmitting the form to us in order to enable us to reply to those contact requests. In the event that you submit your contact information or any other personally identifiable information to us in this way, we will use such information to maintain our business records, manage our relationship with you and to communicate with you and will not disclose such information to any outside party, other than as set out below;

• Your IP address, for the purpose of monitoring access to the Website.

In each case we process your information based on our legitimate business interests to communicate with you and to ensure the security of our Website.

With Whom Do We Share Your Information

To the extent we collect information from visitors to the publicly available areas of our Website through such areas of our Website and/or through emails received from such visitors to the email addresses available on our Website, and/or contact forms transmitted through our web server available on our Website, we do not share such information with any parties outside of our company other than as set out below or when required by a valid subpoena or court order, or as otherwise required by applicable law, regulation, legal or judicial process or audit, decision of a court or arbitral tribunal, decision of a governmental authority with relevant powers, or by the rules of applicable stock exchange or recognized market place, or requested or required by a regulator, bank examiner or self-regulatory organization or pursuant to mandatory ethics rules (together, “Law”).

The data we collect from you via our Website will be transferred to, and stored at, destinations outside the European Economic Area (the “EEA”) including, without limitation, in the United States. It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers set out below. Your personal information is transferred (i) within Bitlogix (as defined below) by way of the European Commission’s standard contractual clauses for the transfer of personal data to third countries, pursuant to Decision 2004/915/EC or by way of the European Commission’s standard contractual clauses for the transfer of personal data to third countries, pursuant to Decision 2010/87/EU (together, the “Model Clauses”) and (ii) to legal and other professional advisers of members of Bitlogix.

We share your personal data collected via our Website with selected third parties. The categories of recipients include the following (which may be updated from time to time):

• Google LLC, based in the United States for the purpose of providing website hosting, and email and storage services;

• Microsoft, based in the United States for the purpose of providing email and storage services;

How Do We Protect Your Personal Information

We maintain operational policies, including physical, electronic and procedural protections, designed to safeguard and secure our data networks against unauthorized access to personal data we may collect through our Website, and have implemented policies designed to ensure that personal information we collect via our Website is used in compliance with this Online Privacy Policy.

Cookies

Like many websites, our Website uses “cookies” to collect information about how the Website is used. A cookie is a small data text file which a website stores on your computer’s hard drive, if permitted by your web browser.

We use cookies to identify you as a unique user when visiting our website, to enable us to track usage so that we can improve the Website, for IT system security purposes and to help us in the ongoing maintenance of our website.

This technology does not provide us with any information about your name, address phone number or email address, or any other personally identifiable information. We do, however, log visitor IP addresses.

Most browsers are initially set up to accept cookies. You can reset your browser to notify you when you have received a cookie, or alternatively, to refuse to accept cookies. However, you may not be able to use certain features on our website if you choose not to accept cookies. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org.

Your Rights

You have the right to ask us to correct your personal data where it is inaccurate or incomplete.

If you are an individual located in the EU, you also have the following rights:

You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we share it with.

In certain circumstances, you have the right to ask us to delete the personal data we hold about you:

• where you believe that it is no longer necessary for us to hold your personal data;

• where we are processing your personal data on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing; or

• where you believe the personal data we hold about you is being unlawfully processed by us.

In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data:

• where you believe the personal data we hold about you is inaccurate and while we verify accuracy;

• where we want to erase your personal data as the processing is unlawful but you want us to continue to store it;

• where we no longer need your personal data for the purposes of our processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or

• where you have objected to us processing your personal data based on our legitimate interests and we are considering your objection.

In addition, you can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.

Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or the interests of any member of Bitlogix (including their proprietary information, trade secrets or intellectual property), or where there are overriding public interest reasons or where we are required by Law or bona fide internal policies and procedures to retain your personal data.

Third Party Websites

Our Website might contain links to websites controlled and maintained by third parties, such as social media networks. We provide these links solely as a convenience for you. These features are recognizable by their third party brand or logo and may collect your IP address and set a cookie to enable the feature to work properly. We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained therein, or the manner in which any information collected on such sites is used. This Online Privacy Policy does not govern the use of information collected on such third party websites.

Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at our main office address in the United States and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with the data protection supervisory authority in the EU country in which you live or work or where you think we have infringed data protection laws.

Changes to This Online Privacy Policy

This Online Privacy Policy was last updated on January 1, 2022. We reserve the right to modify, amend, add to, replace or remove this Online Privacy Policy at any time. Any changes we may make to this Online Privacy Policy in the future will be posted on the Website.