Privacy Policy

We are committed to protecting our visitors’ privacy and we will not collect any personal information about you as a visitor unless you provide it voluntarily. Any personal information you communicate to us is kept within our own records in accordance with the Data Protection Act 2001.

Privacy Policy


CONTENTS

  1. Important information and who we are
  2. The data we collect about you
  3. How is your personal data collected?
  4. Existing Customer
  5. How we use your personal data
  6. Disclosures of your personal data
  7. International transfers
  8. Data security
  9. Data retention
  10. Your legal rights
  11. Glossary


Introduction

Welcome to CC Trading Limited’s privacy notice (the “Notice”).

CC Trading Limited (C 85707) of Ewropa Business Centre, Triq Dun Karm, Birkirkara, Malta (“CC Trading”; “CCTL”; “we”; “us”; “our”) respects your privacy and is committed to protecting your personal information or, as otherwise termed, your “personal data”. In that regard, CC Trading has launched and offers a service which allows clients (subject to prior account registration) to place orders to buy and/or sell those particular cryptocurrencies which may be available to trade from time to time on our online trading platform (the “CCTrader Crypto Platform”) which is accessible via our website www.cctradercrypto.com (the “Site”). To that end, orders are received, processed and executed by CC Trading on behalf of the client (i.e. acting on the client’s instructions) via one of our partnered cryptocurrency exchanges (“CryptoExchange/s”). Through various processes and safeguards, CC Trading strives to ensure that all client orders are accurately processed, and executed in a wholly secure manner (the “CCTL Crypto Services”).

Please refer to our website www.cctradercrypto.com for a more detailed description of the CCTL Crypto Services that we offer.

The purpose of this Notice is to set out the basis on which we will process your personal data when you:

  • visit or access the Site and the CC Trader Crypto Platform (regardless of where you visit or access them from);
  • apply for and open a cryptocurrency account on our CC Trader Crypto Platform (your “CCTrader Crypto Account”);
  • apply for, subscribe to and receive any of our CCTL Crypto Services (e.g. placing and executing orders).

This Notice also informs you about (i) how we will handle and look after your personal data, (ii) our obligations in regard to processing your personal data responsibly and securely, (iii) your data protection rights as a data subject and (iv) how the law protects you. It should be read in conjunction with our IP Address and Cookie Policy available on www.cctradercrypto.com

This Notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version here.

  1. Important information and who we are;
  2. The data we collect about you;
  3. How is your personal data collected;
  4. How we use your personal data;
  5. Disclosures of your personal data;
  6. No international transfers;
  7. Data security;
  8. Data retention;
  9. Your legal rights;
  10. Glossary;
  11. Google Analytics.

 

  1. Important information and who we are

Purpose of this privacy notice

We process your personal data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 440 of the Laws of Malta) (the “Act”), as may be amended or replaced from time to time, and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR” or the “Regulation”).

In that respect, “personal data” means data relating to a living individual who can be identified from the information (data) we hold and/or possess. This includes, but is not limited to, your name and surname (including maiden surname where applicable), address, date of birth, nationality, gender, civil status, tax status, spouse’s name, identity card number & passport number, contact details (including mobile and home phone number and personal email address), bank account details as well as online identifiers. The term ‘personal information’, where and when used in this Notice, shall be taken to have the same meaning as personal data.

This Notice aims to give information on how CC Trading (as defined) collects and processes your personal data in the scenarios outlined above (namely, through your use of the Site, the CCTrader Crypto Platform and any of the CCTL Crypto Services, including any data that you may provide to us, or which we may receive about you, when you instruct us (i.e. place an order) to buy or sell a cryptocurrency that is available to trade on our CC Trader Platform).

The Site, the CCTrader Crypto Platform and the CCTL Crypto Services (collectively) are not intended for minors and we do not knowingly collect personal data relating to minors.

It is important that you read this Notice together with any other privacy notice or policy which we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Notice supplements the other notices and is not intended to override them.

For sake of emphasis, kindly note that you will need to successfully open an account on the CCTrader Crypto Platform (as subject to our approval requirements) to be able to make use of, and receive, any of our CCTL Crypto Services. An account registration and opening will give rise to the existence of a contractual relationship between you and CC Trading Ltd, as regulated by our Terms and Conditions and any use or provision of our CCTL Crypto Services (including transmission, reception and/or execution of any of your orders) will fall within the subject-matter and ambit of that same contractual relationship. Furthermore, the existence of this contract between you and us will also instruct, and serve as the legal basis, for a number of our processing activities involving your personal data, as specified below.

Controller

CC Trading (as defined above) is the controller and responsible for your personal data.

We have appointed a data protection officer (“DPO”) [or Group DPO] who is responsible for overseeing questions in relation to this Notice and our processing activities in general. If you have any questions or requests, including any requests to exercise your legal rights as a data subject, please contact the DPO using the details set out below.

Contact details

Our full details are:

Full name of legal entity: CC Trading Limited (C 85707)

Name of DPO: Ruth Falzon

Email address: [email protected]

Postal address: Level 0, Ewropa Business Centre, Triq Dun Karm, Birkirkara, BKR9034, Malta

Telephone number: +356 25 688 688

You have the right to lodge a complaint at any time with a competent supervisory authority on data protection matters (for example, with the supervisory authority in your place of habitual residence). In the case of Malta, this would be the Office of the Information and Data Protection Commissioner (“IDPC”) (https://idpc.org.mt/en/Pages/Home.aspx). We would, however, appreciate the opportunity to deal with your concerns before you approach that supervisory authority, so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version of the Notice was lasted updated on 09/05/2018.

The data protection laws across the EU, including Malta, will change on 25 May 2018 due to the application of the GDPR. Although this Notice sets out most of your rights under the GDPR, we may not yet be able to respond to some of your requests (for example, a request to have your personal data transmitted to another controller) until the close of May 2018, as we are still working towards adjusting our systems and getting them ready for some of these changes.

It is imperative that the personal data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to provide you with the CCTL Crypto Services which you have requested (amongst other potential and salient issues). Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our 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 notices, statements or policies.

We encourage you to read the privacy notice of every website you visit.

  1. The personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified (as stated above). It does not include data where the identity has been removed (anonymous data).

In the course of your relationship with us (including during account registration and opening stage), we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes your first name, maiden name (where applicable), last name, address, username or similar identifier, marital status, title, nationality, date of birth, gender, identity document type and identity document number, tax domicile, employment status, employer and occupation.
  • Contact Data includes your billing address, email address and contact number (telephone and/or mobile).
  • Account Data refers to your CCTrader Crypto Account information, including any assigned identifiers.
  • Financial Data includes your bank account and payment card details.
  • Transaction Data includes details about:
  • your orders, such as the nature of the order (e.g. whether it is an order to buy or an order to sell), the type of cryptocurrencies involved, the order volume, price, value and, where applicable, the proceeds derived; and
  • your trading and transactional history on the CCTrader Platform.
  • Payment Data includes details about the payments that you receive through us (e.g. withdrawals from your CCTrader Account) or which we receive, or otherwise, charge you (e.g. our commission or brokerage fees).
  • Portfolio Data includes details about the cryptocurrencies and the respective amounts credited to your CCTrader Account, including the applicable conversion into FIAT currency.
  • AML and Risk Data includes the following due diligence / KYC information and documentation about you: (i) copy of I.D. card or passport, (ii) proof of residence (e.g. utility bill), (iii) source of wealth, (iv) criminal records check and (iv) the ‘suitability’ and ‘appropriateness’ data established under MIFID II (e.g. bank statements).
  • Technical Data includes internet protocol (IP) address, your login data to the CCTrader Crypto Platform (username and password), device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and other technology on the devices you use to access the Site and CCTrader Platform.
  • Usage Data includes information about how you use the CCTrader Crypto Platform and our CCTL Crypto Services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Site and/or the CCTrader Platform. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We collect special categories of personal data about you, primarily as a result of the documentation and information that we collect and process in terms of AML and Risk Data. In essence, “special categories of personal data” or, as otherwise termed, “sensitive personal data”, refers to and includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings.

The collection and processing of this sensitive personal data about you is necessary for us to be able to (i) conduct our internal AML and KYC checks and due diligence on you, (ii) verify your identity or claimed identity (a due diligence step which is especially important for us due to the non face-to-face nature of our prospective relationship), (iii) identify any risks that you may present as a prospective customer for us and our services, (iii) assess and determine your risk profile and capacity as an investor (“client risk assessment”) and (iv) ultimately, take a decision on whether we want to, or even should, enter into a relationship with you (based on this information that we collect).

If you fail to provide personal data

Where we need to collect personal data about you:

  • by law; or
  • under the terms of, or in connection with, the contract that we have with you (as discussed in Section 1 above); or
  • as part of our legitimate (business) interests to verify the identity of our applicants and clients, mitigate against risks (such as potential or suspected fraud) and in particular, to assess and take a decision on whether we want to, or even should, enter into a relationship with you (as subject to our client acceptance criteria and policies),

and you either fail to provide that data when requested, or else provide insufficient or unsatisfactory data, we may not be able to perform or conclude the contract that we have or which we are otherwise trying to enter into with you (namely, regarding account openings on our CCTrader Platform and the provision of our CCTL Crypto Services).

In certain instances, particularly where this relates to AML and Risk Data, we may even need to exercise our prerogative to terminate our contract with you in accordance with our Terms and Conditions, and thus withdraw the availability of our CCTL Crypto Services to you, or else, if still at application stage, we may have to decline to enter into a relationship with you. We will however notify you if this is the case at that point in time.

  1. How is your personal data collected?

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

(A)  Account Registration and Opening.

We will ask you to provide us with your Identity, Contact, Financial and AML and Risk Data when you apply to register and open an account with us on our CCTrader Platform (including at account finalisation stage). You provide these personal details and information to us, which we collect and process, when you fill in and submit our application form (together with other related forms), and complete our required application steps.

Your Account Data will be generated on the basis of your application, and is also processed and stored by us.

(B) Service Use.

Through your use of our CCTL Crypto Services, we collect, generate and compile your Financial, Payment, Portfolio and Transaction Data, including in the form of records. The main instances of this are described below.

(i) In the case of orders, you would need to provide us with full details about the order, including its nature and all other related instructions, in order for us to then be able to properly execute that order on your behalf through the assistance of one of our partnered CryptoExchanges. Moreover, once executed, we then receive additional Transaction Data about your order from the CryptoExchange with whom we carried it out (for example, in the case of an order to sell, the price received and applicable proceeds to be credited to your CCTrader Account and, in the case of an order to buy, the amount acquired and the costs of the transaction). The Transaction Data relating to each of your orders is recorded and compiled together so as to establish your trading and transaction history.

(ii) Subsequently, based on the Transaction Data derived and generated from your orders, we then update your Portfolio Data as appropriate (for instance, in the case of an order to sell, the execution price and proceeds that you receive, as confirmed by our CryptoExchange, will then be directly reflected in your Portfolio Data). As set out above, your Portfolio Data represents the type and amount of cryptocurrencies which, at that point in time, have been credited to your CCTrader Account (including value and applicable conversion into FIAT currency) and, in that vein, also represents your trading activity with us and prospective financial returns. Due to cryptocurrency value fluctuations as well as your own trading activities, your Portfolio Data will not be ‘fixed’ but subject to frequent changes and updates.

(iii) Furthermore, we generate, receive and process your Financial, Payment and Portfolio data when you request and receive withdrawals from your CCTrader Account (including the withdrawal amount, its conversion into FIAT currency, your bank account details, and resultant changes to your Portfolio Data), and when we charge and you pay the commission or brokerage fees due to us in connection with your orders and transactions.

Moreover, to act upon service requests, such as orders of a certain volume, we may require you to provide us with further or supplementary AML and Risk Data (for instance, source of wealth information and documentation).

(D) Direct Interactions.

You may also give us your Identity, Contact, Financial, AML and Risk Data, Payment and Transaction Data by filling in our other forms (i.e. separate to our account opening and registration form), or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data that you provide when you, as applicable:

  • subscribe to our CCTL Crypto Services;
  • request withdrawals from your CCTrader Crypto Account;
  • contact us with complaints or queries;
  • report issues;
  • submit the (additional or supplementary) AML and Risk Data that we may request from you;
  • request marketing to be sent to you;
  • participate in a survey; or
  • provide us with feedback.

(E) Automated technologies or interactions.

As you interact with the CCTrader Crypto Platform and the Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy available on www.cctradercrypto.com for further details about this.

(F) Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources, as set out below:

  • . Technical Data from the following parties:
  • (i) analytic providers such as Google;
  • (ii) advertising networks;
  • (iii) search information providers
  • Identity, Contact, AML and Risk Data from publicly available sources like the Malta Registry of Companies, court databases, credit reference databases, as well as through general online searches.
  1. Existing Customer

We have made a concerted effort to ensure that the process for opening and registering an account on our CCTrader Platform is both seamless and straightforward. To that end, we offer we offer an ‘auto-complete’ (or ‘auto-fill’) functionality to the existing customers of either (i) our parent company Calamatta Cuschieri plc (C 70064) and/or (ii) any of its subsidiaries (the “CC Entities” and individually a “CC Entity”). Briefly described, these existing customers can request the relevant CC entity to transfer, and for us to import and receive, the personal information which that CC Entity holds about them at account opening and registration stage. The purpose of this functionality is to provide existing customers with an expedited account opening procedure for the CCTrader Platform.

The use of this functionality will, by design, require the sharing of your personal information from the relevant CC Entity to CC Trading (where you are an existing customer and wish to make use of the auto-complete functionality). The ‘shared’ information will generally comprise your account information with that particular CC Entity, {together with the relevant due diligence information that it may about you and which we strictly require for our own client acceptance and account opening requirements, as indicated above (i.e. limited to our AML and Risk Data)}. These data sharing arrangements are governed by appropriate safeguards and agreements, in line with applicable data protection and privacy requirements and obligations. The security and confidentiality of your personal data remains at all times a paramount concern and priority for the Calamatta Cuschieri Group of entities.

If you wish to utilise this functionality, then your express consent and authorisation to (i) the disclosure of your personal information by the CC Entity and (ii) its receipt by CC Trading, will be requested (namely, via a click-through appearing on the relevant webpage). Your consent is required in order to enable the sharing of this information at law – primarily, due to professional secrecy considerations which underlie the permitted use and disclosure of your due diligence information. Therefore, in the absence of your consent, we will unfortunately not be in a legal position to make this particular functionality available to you, and you will need to manually complete our account opening and registration steps (including in terms of filling in the relevant forms).

Kindly note that, in the given scenario, consent and authorisation would be requested for the sharing of your information (i.e. disclosure) from the CC Entity to CC Trading. In that regard, where you do provide your consent and authorisation, we will process the information that we receive from the CC Entity pursuant to the lawful bases set out in Section 5, as applicable (i.e. performance of a contract, legitimate interests or compliance with a legal obligation).

  1. How we use your personal data

We will only use your personal data when the law allows us to. 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 in respect of your customer relationship with us.
  • Where it is necessary for our legitimate interests (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 or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to such marketing at any time by contacting us, as indicated below.

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 which of 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 for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at [●] if you need details about the specific legal ground 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 including basis of legitimate interest

To conduct due diligence checks on you (following your application to open and register an account).

To then decide on your application to open an account on the CCTrader Platform and, if positive, to enter into a relationship with you and to register (on-board) you as a new customer.

(a) Identity;

(b) Contact;

(c) Financial;

(d) AML and Risk Data;

(e) Applicant.

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests, including to establish and verify

– your identity and suitability for our CCTL Crypto Services,

– the existence of any risks that you may present as a prospective customer,

– your ability to meet financial commitments,

and ultimately, to enable us to take an informed decision on whether we should enter into a relationship with you.

Assess and determine your risk profile and capacity (both prior to account registration and as an ongoing process during your relationship with us)

 

 

 

 

(a) Identity;

(b) AML and Risk Data (namely, information relating to your financial situation, and knowledge and experience).

 

 

 

 

(a) Performance of a contract with you.

(b) Necessary for our legitimate interests as well as your own, to enable us to in particular:

– ascertain your suitability for our CCTL Crypto Services and investment trading (both in respect of cryptocurrencies and generally);

– advise you on your risk capacity;

– manage your portfolio in a manner appropriate to you and your risk profile and capacity;

– provide you with suitable investment advice;

– prevent you from exceeding your risk capacity or from over-extending yourself financially.

(a) To enable your use of the CC Trader Platform and provide you with the CCTL Crypto Services that you may request, including in particular to

– process and execute your orders;

– inform you about the execution price of the order and any proceeds;

– credit your CCTrader Account;

– update your portfolio;

– convert the cryptocurrencies credited to your account into FIAT currency;

–  effect withdrawals from your CCTrader Account to your designated bank account.

(b) Manage transactions and generate transaction reports and records.

(c) Manage payments, fees, charges.

(d) Collect and recover money which is owed to us (debt recovery).

(a) Identity;

(b) Contact;

(c) Applicant;

(d) Financial;

(e) Payments

(f) Portfolio;

(g) Transaction.

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us).

 

For legal, tax and accounting purposes (e.g. reporting to tax authorities, and accounting record requirements).

 

 (a) Payments; and

(b) Transaction.

(a) Necessary to comply with a legal obligation
To prevent and report fraudulent or suspicious orders/transactions.

(a) Identity;

(b) Contact

(c) Applicant

(d) AML and Risk Data;

(e) Payments;

(f) Portfolio;

(g) Transaction.

 

 

(a) Necessary for our legitimate interests, including in particular to:

– protect the reputation of our business;

– avoid any complicity or association with fraud;

– report fraudulent or otherwise suspicious orders that we receive (or which later came to our knowledge) to relevant public authorities.

 

 

To manage our relationship with you, including in particular to

(a) notify you about changes to our terms or privacy notices;

(b) respond to complaints, queries and/or reported issues;

(c) deal with your requests;

(d) ask you to participate in a survey;

(e) request feedback from you.

(a) Identity;

(b) Contact;

(c) Usage; and

(d) Marketing and Communications.

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (for ‘customer care’ and service matters, to study how clients user our services, to assess our operations, to develop them and grow our business).

 

To administer and protect our business, including the CCTrader Platform and the Site, (including troubleshooting, data analysis, testing, system maintenance, support, safety and security testing, reporting and hosting of data).

(a) Identity;

(b) Contact;

(c) Technical;

(d) Account.

(a) Necessary for our legitimate interests (for running and administering our business, network security, to prevent fraud and to ensure secure processing and transmission of orders, and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation.

(c) Performance of a contract with you, namely to ensure:

– that your orders are able to be securely processed and transmitted

– the confidentiality of your CCTrader Account and Portfolio Data.

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

To ensure that our content is presented in the most effective manner for you and your computer and devices, and in a user friendly manner.

(a) Identity;

(b) Contact;

(c) Account;

(d) Usage;

(e) Marketing and Communications;

(f) Technical.

Necessary for our legitimate interests (to study how clients use our services and trading platform, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve the Site and trading platform, marketing, customer relationships and experiences.

(a) Technical;

(b) Usage.

Necessary for our legitimate interests (to define types of clients and investors (e.g. institutional) that have registered an account on our CCTrader Platform and use our CCTL Crypto Services, to keep the Site and the trading platform updated and relevant, to develop our business and to inform our marketing strategy).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around advertising and marketing communications. Through your Account, Identity, Contact, Technical and Usage Data, we can form a view on what we think you may want or need and what may be of interest to you. This would then enable us to determine which of our particular services may be most relevant for you (we call this marketing).

In that regard, will only send you advertising and marketing communications:

  • if you have entered into a customer relationship with us (by opening an account on our CC Trader Platform),
  • if you actually make use of our CCTL Crypt Services and are thus an existing and ongoing customer; and
  • provided you have not opted out of receiving marketing from us (see Your Legal Rights below).

Opting out

You can ask us to stop sending you advertising and marketing communications at any time by:

  • following the opt-out links on any marketing message sent to you;
  • contacting us at any time at via the contact form on cctradercrypto.com or the Chat function on the CCTrader crypto platform

Where you opt out of receiving such communications, this will not apply to personal data processed or provided to us as a result of your entry into a banking relationship with us and our service provision.

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 via the contact form on cctradercrypto.com or the Chat function on the CCTrader crypto platform

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 the need to obtain your consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 5 above.

  • External Third Parties as set out in the Glossary.
  • Public authorities as set out in the Glossary.
  • Our subsidiaries, associates and agents where necessary to facilitate your relationship with us and/or enable the provision of the CCTL Crypto Services that you have requested from us.
  • 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 Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law (including applicable data protection and privacy law). We do not allow our third party business partners or 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. Furthermore, these third parties access and process your data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards.

We may also disclose your data if we are under a duty to disclose or share your personal data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority.

We may also disclose your data to enforce our contractual terms with you, or to protect our rights, property or safety, that of our partners or other users of the CCTrader Platform and our CCTL Crypto Services. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

  1. International transfers

We do not transfer your personal data to outside the European Economic Area (“EEA”), except as may be required to provide you with the CCTL Crypto Services that you request from us (i.e. contractual performance).

Should we need to transfer your personal data to outside of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • In the absence of an adequacy decision, we will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us at [·] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.

 

  1. Data retention

How long will you use my personal data for?

Please note that we (CC Trading) consider our relationship with you to be an ongoing and continuous customer relationship, until such time that either we or you terminate it in accordance with our terms and conditions

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (i.e. the ongoing service provision) and, thereafter, for the purpose of satisfying any legal, accounting, tax and reporting requirements and obligations to which we may be subject and/or to the extent that we may also need to retain your personal data to be able to assert, exercise or defend possible future legal claims against or otherwise involving you.

By and large, our retention of your personal data shall not exceed the period of six (6) years from the date of the termination of your relationship with us (which would typically arise from the closure/de-registration of your account on the CC Trader Platform).  This period of retention enables us to use the data in question for the defence of possible future legal claims (taking into account the timeframe of applicable statutes of limitation and prescriptive periods). In certain cases though, we may need to retain your data for a period of up to ten (10) years in order to comply with applicable accounting and tax laws (this will primarily consist of your Transaction and Payment Data).

[AML AND RISK DATA]

In some circumstances, you can ask us to delete your data. See Request erasure below for further information.

Kindly contact our DPCP for further details about the retention periods that we apply.

Data Minimisation

Whenever and to the extent possible, we anonymise the data which we hold about you when it is no longer necessary to identify you from the data which we hold about you (anonymous data).

In some circumstances, we may even anonymise 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

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at Level 0, Ewropa Business Centre, Triq Dun Karm, Birkirkara, BKR9034, Malta or via email on [email protected].

These rights are explained below under Section 11.

No fee usually required

You will not normally have to pay a fee to exercise your data subject rights.

However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in the above circumstances.

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 data subject 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 may 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.

  1. Glossary

Lawful Basis

Legitimate Interest means our interest to conduct and manage our business appropriately and responsibility, to protect the reputation of our business, and to provide our clients with the best service provision and the best and most secure 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 at [–].

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

External Third Parties

  • CryptoExchange partners, whom we use to carry out and execute our clients’ orders (including yours).
  • Professional advisers, including external legal counsel, auditors and consultants and insurers whom we engage to provide us with legal, insurance, auditing and accounting services from time to time.
  • Debt recovery agencies who assist us with the recovery of debts owed to us.

 

Public Authorities

Commission of Inland Revenue, regulators, law enforcement agencies and other authorities who require reporting of processing activities, or may request information from us, in terms of applicable law and in certain circumstances.

Your Legal Rights

You have the right to:

  1. 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.

You may send an email to [email protected] requesting information as the personal data which we process. You shall receive one copy free of charge via email of the personal data which is undergoing processing. Any further copies of the information processed shall incur a charge of €25.

  1. Right to information when collecting and processing personal data about you from publicly accessible or third party sources. When this take places, we will inform you, within a reasonable timeframe, about the third party or publicly accessible source from which we have collected your personal data.

iii. Request correction or rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected and/or updated, though we may need to verify the accuracy of the new data you provide to us. As mentioned, it is in your interest to keep us informed of any changes or updates to your personal data which occur during the course of your relationship with us.

  1. 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 have successfully exercised your right to object to processing (see below);
  • we may have processed your information unlawfully; or
  • 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. In particular, notwithstanding a request for erasure, we may continue to retain your personal data where necessary for

  • compliance with a legal or regulatory obligation to which we are subject; or
  • the establishment, exercise or defence of legal claims.
  1. 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 (as under the Marketing in Section 5).

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  1. 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; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

vii. Request the transfer (data portability) 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.

  1. Withdraw consent at any time where we are relying on consent to process your personal data (which will not generally be the case). This will not however affect the lawfulness of any processing which we carried out before you withdrew your consent.

Conclusion

We reserve the right to make changes to this Notice in the future, which will be duly notified to you. If you have any questions regarding this Notice, or if you would like to send us your comments, please contact us today or alternatively write to us using the contact details on our website.

 

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