SENSITIVE AND CONFIDENTIAL DATA
We will not intentionally collect or maintain, do not want you to provide, and will never ask you for any information regarding medical or health conditions, race or ethnic origin, political opinions, religious or philosophical beliefs nor any other confidential information (eg. credentials, private keys, PIN code). Please prevent from disclosing to us or to any third party any sensitive personal data relating to you or any other person.
How long do we keep your information?
In accordance with the storage limitation principle set forth under Applicable Laws, we endeavor to retain data for no longer than the time required to achieve and comply with such legitimate and legal purposes, including satisfying any legal, accounting, tax, or other compliance reporting requirements.
We may archive some of your personal data, with restricted access, for an additional period of time when it is strictly necessary for us to comply with our legal and/or regulatory archiving obligations and for the applicable statute of limitation periods. At the end of this additional period, your remaining personal data will be permanently erased or anonymized from our systems.
Where cookies or other technical tracking technologies are placed on your computer or when we process your Browsing Data, we keep them for as long as necessary to achieve their purposes (e.g. for the duration of a session for session ID cookies) and for a maximum period defined in accordance with Applicable Laws.
If you contact us as part of an inquiry, we keep your personal data, notably your Contact Details, for as long as necessary to process your inquiry.
If you purchased a product or a service from us, we may retain some transactional data attached to your Contact Details to comply with our legal, tax, or accounting obligations for a maximum 10 years period set forth by Dutch applicable laws, as well as to allow us to manage our rights (for example to assert our claims in Courts) during applicable Dutch statutes of limitations.
Who may we share your information with?
We may also transmit some of your data to third parties such as payment services, infrastructure, logistics, and other services providers.
In certain circumstances and only where required by Applicable Laws, we may disclose some of your data to competent administrative or judicial authorities or any other authorized third party.
What are your rights regarding your personal data?
You can withdraw your consent to receiving our marketing emails by clicking on the “Unsubscribe” link at the bottom of the emails we sent you.
You have the right to request access to the personal data we retain about you, their rectification or erasure, as well as the right to request the restriction of the processing or to object to the processing of your personal data.
You also have the right to request a copy, in an interoperable format (right to your data “portability”), of the personal data that you have provided to us for the performance of a contract with us or under your sole consent.
Finally, Dutch data subjects also have the right to set general or specific guidelines regarding the fate of their personal data in the event of death and to change them at any time. They have the option to register such guidelines with a digital trusted third party certified by the Dutch data protection authority.
If you object to the processing or ask for the erasure of your personal data by Crayonic, we shall acknowledge the receipt of your request and, within a maximum one month period, we shall stop processing your personal data or erase it from our IT systems, except where Crayonic has legitimate and compelling grounds for the processing, or for the purpose of ascertaining, exercising or defending its legal rights in accordance with the Applicable Laws. If necessary, Crayonic shall inform you of the legal grounds and reasons why your request could not be satisfied in whole or in part.
To exercise any of the abovementioned rights, please send us a request using the below Contact Information. We will take steps to verify your identity, to ensure, with a reasonable degree of certainty, that you are at the origin of the data subjects’ right request. When feasible, we will match personal data provided by you in submitting a request to exercise your rights, with other information already maintained by Crayonic, this could include matching two or more data points you provide us. In some instances, when the matching cannot establish your identity, we can request you to provide a copy of a formal identification document.
If you wish to access, correct, modify or delete the personal information we have about you, object to their processing, exercise your right to portability, file a complaint, exercise any of the above-mentioned rights, or simply obtain more information about the use of your personal data, please contact Crayonic and its privacy Team at privacy[at]crayonic[dot]com
Crayonic will endeavor to find a satisfactory solution to ensure compliance with the Applicable Laws.
In the absence of a response from Crayonic or if you are not satisfied by Crayonic's response or proposal or at any moment, you have the ability to lodge a complaint before the Dutch data protection authority or with the supervisory authority of the Member State of the European Union of your country of residence.
How do we secure personal data?
In order to ensure the integrity and confidentiality of your personal data, we implement appropriate physical, electronic, and organizational procedures to safeguard and secure personal data throughout our Services.
In particular, Crayonic implements necessary technical and organizational measures, in order to ensure the security and confidentiality of your personal data collected and processed, and particularly, to prevent your personal data from being distorted, damaged, or communicated to unauthorized third parties, by ensuring an appropriate level of security with regards to the risks associated with the processing and the nature of the personal data to be protected.
We notably implement the following security measures, among others:
Payment Data security: If you provide us with credit card information, such information is encrypted using a secure Internet Trade Protocol (TLS) and sent directly to our Payment Service Provider (PSP). This information is never stored on our server.
Awareness program and employee training
Data encryption in transit and at rest
Data centers routinely audited
Data redundancy for resilience in case of disasters
Two-factor authentication of our authorized employees
Continuous system monitoring
Industry-standard security evaluations
Independent third-party security reviews and penetration tests
While we endeavor to provide best-in-class protection for your personal data when you use our Services, please keep in mind that the transmission of information on the Internet is not fully secure.
You remain responsible for keeping your personal credentials, passwords, PIN codes, Payment Data, recovery phrases confidential and secure as Crayonic does not have access to that information.
How do we transfer your personal data outside of the EEA?
Personal data that we collect from you may be stored and processed in, and transferred to, countries outside the European Economic Area (EEA). For example, this could happen if our servers are located in a country outside the EEA or if one of our service providers is located in a country outside the EEA. These countries may not have data protection laws equivalent to those in force in the EEA.
If we transfer personal data outside the EEA this way, we will take the necessary steps to ensure that your personal data continues to be protected in compliance with the Applicable Laws, notably by only transferring your personal data to businesses established in countries recognized by the European Commission as providing an adequate level of protection for your personal data or to organizations with whom we have entered into contractual arrangements to ensure appropriate protection of your personal data, including the European Commission standard contractual clauses or that commit themselves to apply a code of conduct or a certification mechanism validated by the competent European authorities.
Please note that in light of the “Schrems II” European Court of Justice decision (C-311/18) released on July 16, 2020, invalidating amongst other things the so-called “EU-US Privacy Shield arrangement”, Crayonic is currently reviewing, analyzing, and will apply guidelines of the European Data Protection Board as of July 24, 2020, in order to appropriately keep on ensuring an adequate level of protection of your privacy and your personal data processed by our service providers established in the USA or outside of the European Economic Area and relying on their Privacy Shield certifications as monitored by the US Federal Trade Commission. We are confident that Ledger’s long-standing security and privacy culture will enable us to identify and apply appropriate solutions to continue serving our clients globally and on both sides of the Atlantic with trust and security and without interruption.
For more information on the safeguards put in place, please contact us.
Unless otherwise agreed, no delay, act, or omission by a party in exercising a right or remedy will be deemed a waiver of such right, or of another right or remedy.
In the event Crayonic is the subject of a corporate transaction such as an acquisition or merger with another company, your information may be transferred to the new owners so that we can continue to provide our Services to you. We will, in any case, take steps to protect your privacy.