Privacy Policy

As of 27 December 2021

1. INTRODUCTION

Bull Global Ltd. (the “Company”) respects and is committed to safeguarding the privacy of the registered users of the Bull Global platform and other related services (the “Services”). This Platform Privacy Policy (“Privacy Policy”) governs how we will collect, use, manage, secure, and store your data when visiting our website, opting to participate in the Company’s services, or sign up for periodic email communications. This Privacy Policy also aims to provide information regarding your privacy rights as well as other applicable laws.

By using the Company’s website, you consent to the data practices described in this Privacy Policy. If you do not consent to the provisions outlined in this Privacy Policy, please cease using this website immediately. This Privacy Policy may change from time to time, and any alterations to the policy that may materially affect your rights or how we process your personal data will be announced accordingly. 

Children under 18 years of age are not permitted to use this website, and we do not knowingly collect data relating to children.

It is important that you read this Platform Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we collect or process personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.


2. IMPORTANT INFORMATION AND WHO WE ARE  


COLLECTION OF YOUR PERSONAL DATA

Personal data, or personal information, refers to any information which are linked or related to an identified or identifiable individual. We may collect, use, store, and/or transfer different types of personal data about you, including:

Personally Identifiable Data such as your first name, maiden name, last name, marital status, title, date of birth, and gender;

Contact Information such as your postal address, email address, social media, and telephone number;

Financial Data including your electronic or digital wallet details;

Transaction Data including details about payments to and from you as well as information regarding products and services you have purchased from us;

Technical Data such as your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technologies on the devices you use to access this website;

Profile Data including your username and password, purchases or orders you have made, your interests, preferences, feedback, and survey responses;

Usage Data such as information on how you use our website, products, and services; and

Marketing and Communications Data such as your preferences for receiving marketing materials and alerts from us and our affiliates, as well as your communications preferences.

We may also collect, use, store, or share Metadata such as statistical or demographic information. Metadata could be from you but legally is not considered personal data as this data does not, directly or indirectly, reveal your identity. For example, we may aggregate your Usage Data to calculate the number of users accessing a specific website feature. However, in the event that we combine or connect Aggregated Data with your personal data in order to identify you directly or indirectly, we will treat the combined data as personal data and will be used in accordance with this privacy policy.

Unless given explicit consent, we will not collect any Special Categories of Personal Data about you (including details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data among others). We will likewise not collect any information about criminal convictions and offences.


CONTROLLER  

The Company is the controller and entity responsible for controlling, storing, and securing your personal data. Any third parties that handle your personal information, in accordance with our instructions, are considered our service providers (“Data Processors”).

We have appointed a Data Protection Officer (the “DPO”) who is responsible for overseeing and handling questions, requests, feedback, and suggestions in relation to this Privacy Policy. If you have any questions regarding this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.


CONTACT DETAILS  

If you have any questions about this Privacy Policy or any of our privacy practices, please contact our data privacy managers. Their contact details are as follows:

Full name of legal entity: Bull Global Limited

Email address: BULC@silklegal.com

Postal address: Craigsmuir Chambers, Road Town, VG1110, British Virgin Islands

You have the right to lodge a complaint at any time to the supervisory authority for data protection. Any inquiries or complaints regarding this privacy policy should first contact us at: BULC@silklegal.com


CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES  

We keep our Privacy Policy under regular review, and will update it from time to time, which will be indicated by changing the date at the top of this page. Any updates to the Privacy Policy will be sent to the email address associated with your account prior to the change becoming effective, or as otherwise required by law.

It is important that the personal data you have provided us is accurate and up to date. Please keep us informed of any changes to your personal data throughout the time you use the Company’s services, opt for email communications, or any in the event you maintain any type of relationship with us.


THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.


FAILING TO PROVIDE PERSONAL DATA  

Where we are required to collect personal data, whether by law or under the terms of a contract we have with you, and you fail to provide that data upon request, we may not be able to deliver a product or perform a service expected of us. In this case, we may have to cancel delivering the product or service to you, although we will notify you before such an instance.


3. HOW IS YOUR PERSONAL DATA COLLECTED?


We use different methods to collect data from and about you including through:

1. Direct interactions. You may give us your Personally Identifiable Data, Contact Information, and Financial Data by filling in forms provided or by directly corresponding with us by post, phone, email, or any other method. This includes personal data you provide when you:

1. apply for our products or services;

2. create an account on our website;

3. subscribe to our service or publications;

4. enter a competition, promotion, or survey; or

5. give us feedback or contact us.

2. Automated technologies or interactions.
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, browser trackers, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies or embedding elements of our site. Please see our cookie policy for further details.

3. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Advertising Networks & Analytics Provider: We work with these providers to provide us with de-identified information about how you found our Sites and how you interact with the Sites and Services and;

Technical Data from the following parties:

Joint Marketing Partners & Reseller, unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that we can better understand which of our Services may be of interest to you

Contact, Financial and Transaction Data from providers of technical, payment, and delivery services;

Personally Identifiable Data and Contact Data from data brokers or aggregators.

Personally Identifiable Data and Contact Data from publicly available sources, such as Companies House, and the Electoral Register based inside the EU.

Blockchain Data: We may analyze public blockchain data to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms, and to analyze transaction trends for research and development purposes.

4. HOW WE USE YOUR PERSONAL DATA


We will only use your personal data when we have a legitimate lawful basis. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract, we are about to enter into or have entered into with you.

Where it is 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 a legal obligation.

We have or may have a lawful basis to process your personal data in the following circumstances:

“Legitimate Interest” — In the interest of conducting and managing our business to enable us to provide you the products and services, including providing a secure online experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of Contract” — In order to enter into or perform a contract with you, or to take steps at your request before entering into such a contract.

“Comply with Legal Obligation — When necessary for us to comply with a legal obligation, including laws, regulations, rules, whether issued by a national government, a subdivision of a government such as a state or city, or a supra-national government such as the UN or EU.

To engage in marketing activities — Based on your communication preferences, we may send you marketing communications (e.g. emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law. 

For research and development purposes — We process your personal information to better understand the way you use and interact with the Company’s services. In addition, we use such information to customize, measure, and improve the Company’s services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.

To ensure quality control — We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.

To detect and prevent fraud and/or funds loss — We process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or funds loss.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.


PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing your data

To register you as a new customer

Identity

Contact

Performance of contract

To process and deliver your order including:

Manage payments, fees and charges

Collect and recover money owed to us

Identity

Contact

Financial

Transaction

Marketing and Communications

Performance of contract

Legitimate interest (to recover debts due to us)

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy policy

Asking you to leave a review or take a survey

Identity

Contact

Profile

Marketing and Communications

Performance of contract

Legal obligation

Legitimate interest (to keep our records updated and study how customers use our products/services)

To enable you to partake in a prize draw, competition, or complete a survey

Identity

Contact

Profile

Usage

Marketing and Communications

Performance of contract

Legitimate interest (to study how customers use our products/services, develop and improve our products/services, and expand our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)

Identity

Contact

Technical

Legitimate interest (for running our business, provision of administration and IT services, network security, fraud prevention, and in the context of a business reorganization or group restructuring exercise)

Legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Identity

Contact

Profile

Usage

Marketing and Communications

Technical

Legitimate interest (to study how customers use our products/services, develop and improve our products/services, develop our business, and inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Technical

Usage

Legitimate interest (to define types of customers for our products and services, update our website, develop our business, and inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Identity

Contact

Technical

Usage

Profile

Marketing and Communications

Legitimate interest (to develop our products/services and expand our business)

MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  


PROMOTIONAL OFFERS FROM US  

We may use your Identity, Contact, Technical, Usage and Profile Data for marketing purposes, including to form a view on what products, services, and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing.


THIRD-PARTY MARKETING  

We will not share your personal data with any third party for marketing purposes without your express opt-in consent.


OPTING OUT  

You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences. You may also opt out of having your personal information shared with third parties or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase. In addition, the limitation of the use of your personal information, certain features or the Company’s services may not be available to you.


COOKIES  

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please refer to our cookies policy. 


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.

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 the above rules, where this is required or permitted by law.


5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table (“Purposes for Which We Will Use Your Personal Data”) above.

The following internal and external third parties:

The issuer of Bullcoin tokens;

Service providers who provide IT and system administration services;

Professional advisers including lawyers, bankers, auditors, and insurers based outside the British Virgin Islands who provide advisory, technical, consultancy, accounting, tax, and legal services; and

Revenue and customs authorities and regulators in the British Virgin Islands.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


6. INTERNATIONAL TRANSFERS  


We may share your personal data within the Bull Global group of companies. This may involve transferring your data to other jurisdictions, including outside the British Virgin Islands, (or, for our customers inside the European Economic Area (EEA)), jurisdictions outside the EEA.

Many of our external third parties are based in other jurisdictions, including outside the British Virgin Islands, or for customers inside the EEA, outside the EEA, so their processing of your personal data will involve a transfer of data outside the British Virgin Islands and the EEA. 

Whenever we transfer your personal data to other jurisdictions, we seek to ensure a similar degree of protection is afforded to it by requiring our third-party partners to enter into contracts requiring them to adhere to the terms of this Privacy Policy.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data to other jurisdictions.


7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


8. DATA RETENTION

HOW LONG WILL YOUR PERSONAL DATA BE USED FOR?  

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see Section 9 (“Your Legal Rights”) below for further information.

In some circumstances we will anonymize 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.


9. YOUR LEGAL RIGHTS


You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that 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.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.

Where our use of the data is unlawful, but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you would like to take advantage of any of your legal rights, please contact us.


NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.


PERSONAL DATA BREACH POLICY 

Where a breach of your personal data occurs, we will inform you as soon as practicable or necessary, however, if such a breach is relevant to your sensitive personal data, we will inform you of such breach within 72 hours. Once the problem has been resolved, you will once again be made aware. 

Only those directly affected will be informed of such a breach by Bull Global.


WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.