Privacy Policy

At CryptFolio, we are committed to your right to privacy, and take your privacy seriously.

1. Introduction

CryptFolio Limited (we, us, our) complies with the New Zealand Privacy Act 1993 (the Act) when dealing with Personal Information. Personal Information is information about an identifiable individual (a natural person).

This policy sets out how we will collect, use, disclose and protect your Personal Information.

This policy does not limit or exclude any of your rights under the Act. If you wish to seek further information on the Act, see www.privacy.org.nz.

2. Changes to this policy

We may change this policy by uploading a revised policy onto the website. The change will apply from the date that we upload the revised policy.

3. Who do we collect your Personal Information from

We collect Personal Information about you from:

1. you, when you provide that Personal Information to us, including via the website and any related service, through any registration or subscription process, through any contact with us (e.g. telephone call or email), or when you buy or use our services and products
2. third parties where you have authorised this or the information is publicly available.

If possible, we will collect Personal Information from you directly. Whenever we request Personal Information, our goal is to be clear about what information we are collecting, why we are collecting it, and how that information will be used.

3.1. Personal Information we collect

As is standard industry practice, our web servers temporarily store information about each request. This information is collected so that we may work on server problems, and prevent malicious visitors from abusing our website, so that we can continually improve our website. This temporary data is aggregated into an anonymous format and deleted within three months. We collect the following information from your requests: the date and time, the originating IP, the type of browser and operating system used, the URL of the referring page, the object requested, and the completion status of the request.

You may choose to sign up for a CryptFolio account. We will then collect the following Personal Information from you:

1. your IP address: to prevent abuse, and to satisfy the requirements of local and international tax law.
2. your billing country: to provide an optimal user experience, to identify your billing currency, and to satisfy the requirements of local and international tax law.

At your direction, we may also collect the following Personal Information:

1. your name: to optionally personalise your experience and the communications that we send you.
2. your email address: to contact you with important service updates, to optionally add you to our mailing lists, to optionally send you portfolio notifications, and to optionally enable 2FA authentication.
3. your third-party OAuth credentials: to optionally enable signup and logging with third parties.
4. if you choose to use one of our mobile apps, your mobile device model, timezone, and language: to help you manage your authenticated devices, and to personalise your experience
5. your addresses, accounts, and balances, including their keys, secrets, and other access information: to provide our portfolio services to you. We use this information to construct balances and histories of your portfolio, which may then be used in charts, notifications, and your private API.

4. How we use your Personal Information

We will use your Personal Information:

1. to verify your identity
2. to provide services and products to you
3. to market our services and products to you, including contacting you electronically (e.g. by text or email for this purpose)
4. to improve the services and products that we provide to you
5. to bill you and to collect money that you owe us, including authorising and processing credit card transactions
6. to respond to communications from you, including a complaint
7. to conduct research and statistical analysis (on an anonymised basis)
8. to protect and/or enforce our legal rights and interests, including defending any claim
9. for any other purpose authorised by you or the Act.

5. Disclosing your Personal Information

We may disclose your Personal Information to:

1. any business that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the website or other services and products, for the purpose of providing the website or other services and products
2. other third parties (for anonymised statistical information)
3. a person who can require us to supply your Personal Information (e.g. a regulatory authority)
4. any other person authorised by the Act or another law (e.g. a law enforcement agency)
5. any other person authorised by you.

A business that supports our services and products may be located outside New Zealand. This may mean your Personal Information may be held and processed outside New Zealand.

5.1. Google Analytics

We may collect information about your activity on the website using the third party tool Google Analytics. This information is collected so that we may identify page popularity, site performance, user activity, and user interface issues, so that we can continually improve our platform and your user experience. This information is stored securely by Google, as detailed in their Data privacy and security policy.

User and event data collected with Google Analytics is retained for up to 26 months, as per their data retention policies. You may choose to opt-out for Google Analytics.

5.2. Bing Ads

We may collect information about your activity on the website using the third party tool Bing Ads. This information is collected to optimise our advertising campaigns and cannot be used to identify you. This information is gathered anonymously by Bing Ads, as detailed in their Microsoft Bing Ads privacy policy.

5.3. CoinPayments.net

The CryptFolio website does not receive or store your cryptocurrency payments. When you purchase a service on this website with cryptocurrency, you will be redirected to our payment gateway CoinPayments.net, who will securely process your cryptocurrency payment details and Personal Information. For more information about the policies of our payment provider, please visit the CoinPayments.net website.

5.4. Stripe

The CryptFolio website does not receive or store your credit card payments. When you purchase a service on this website with a credit card, you will be redirected to our payment gateway Stripe, who will securely process your credit card details and Personal Information. For more information about the policies of our payment provider, please visit the Stripe website.

5.5. OneSignal

If you choose to use one of our CryptFolio mobile apps for Android or iPhone, then your device will be registered with OneSignal, so that we can optionally send you push notifications. We will share your user ID and email address with the platform to connect your device with your CryptFolio account. For more information about how OneSignal uses your data, please review the OneSignal privacy policy.

5.6. Private API

If you have permitted third-party applications to access your account through your private API, your Personal Information may be exposed. It is your responsibility to keep your API access tokens secure and regularly review your authorised applications.

6. Protecting your Personal Information

We will take reasonable steps to keep your Personal Information safe from loss, unauthorised activity, or other misuse.

7. Accessing and correcting your Personal Information

Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable Personal Information that we hold and to request a correction to your Personal Information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the Personal Information relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the Personal Information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the Personal Information that you requested the correction.

If you want to exercise either of the above rights, email us at privacy@cryptfolio.com. Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Information, or the correction, that you are requesting).

We may charge you our reasonable costs of providing to you copies of your Personal Information or correcting that information.

If you have created a user account, at any time you may download a copy of all of the Personal Information that we hold about you. You may also choose to delete your account at any time, which will permanently and irreversibly remove all data associated with the account. We will not have access to any data deleted in this way.

8. Internet use

While we take reasonable steps to maintain secure internet connections, if you provide us with Personal Information over the internet, the provision of that information is at your own risk.

If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your Personal Information. We suggest you review that site’s privacy policy before you provide Personal Information.

We use cookies (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) to monitor your use of the website. You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website.

9. More information

If you have any questions at all about our privacy policy, or if you would like to make a formal complaint, please contact our Privacy Officer with any details and/or any supporting documentation:

• by secure mail to The Privacy Officer, CryptFolio, 216a Willis St, Wellington 6011, New Zealand, or
• by e-mail at privacy@cryptfolio.com.

Last updated: October 2018