PRIVACY policy

Privacy Policy

We would like to inform you about the nature, scope and purpose of the collection and use of your personal data when using our Services on our website www.cryptotresorbank.com (the “Website”), which CryptoTresor Bank PTE, Marina Bay Financial Centre, Downtown Core, Central Region, Singapore, provides.

 

I. Data Processing for the purposes of our Website

If you visit our Website for informational purposes without signing up for the Platform, CryptoTresor Bank will be considered the sole controller within the meaning of the Singaporean data protection regulation (SDPR) for any processing related to your visit.

 1. Collection and processing of data:

CryptoTresor Bank gathers, uses and saves your personal data to provide access to the Website. 
This includes any information you provide manually as well as technical information that is required for the communication between your end-device and our applications.

Technical Data

The technical information we collect for our website www.cryptotresorbank.com includes:

  • Email Address
  • IP Address (anonymised)
  • Evaluation of website activity and internet usage
  • User website activity on the website and the location they came from (e.g. URL and referrer)
  • Operating system 

With every access to our Website, usage data are transmitted through the respective internet browser and stored in log files, the so-called server log files. The records stored in this case contain the following data: date and time of retrieval, page name, IP address, referrer URL (i.e. the page you have previously visited), the amount of data transferred, as well as the product and version information of the browser used. The IP addresses of users will be deleted or anonymized after the end of use. In the case of anonymization, the IP addresses are changed in such a way that the details of personal or factual circumstances can no longer be assigned to a specific or identifiable natural person, or only with a disproportionate amount of time, cost and manpower.
We use the log data and log files only for statistical evaluations for the purpose of operation, security and optimization of our offer.

Additionally you may provide us certain information by your own choice to use certain features of our Website.

Newsletter

With our Newsletter we inform you about important product updates , special announcements and our offers. To register for the newsletter, we need your e-mail address. In addition, we record your IP address and the date of registration upon registering to ensure that no third party misuses your e-mail address and hereby logs in without your knowledge to receive the newsletter. This data is stored and used for the sending of the newsletter. After registering, you will receive an e-mail to confirm your affiliation to the newsletter e-mail list. Unless you confirm your registration for our newsletter within 24 hours, we will delete your provided data for signing up for the newsletter (email address, IP address, date of registration) 24h after sending out the confirmation e-mail, provided that no statutory storage requirements are in conflict.

At the end of each newsletter, there is a link through which you can unsubscribe from the newsletter at any time.

Additionally we, collect certain data on your interactions with our Newsletter, using graphic elements integrated in each Newsletter (so called Pixels). We use these data in pseudonymised form for general statistical evaluation and to optimize our customer communication further.

You can revoke your consent or object to the storage of data, the e-mail address and their use for sending the newsletter at any time. The revocation or objection can be declared via a link in the newsletter itself.

Questionnaire

With our surveys and questionnaires, we would like to adapt and improve the service offering to the needs of our participants. You can participate in our surveys by clicking on a button on our website. If you participate in a survey, we will store your e-mail address and your name so that we can identify you and classify you in the pre-signup list.

In the survey we collect and process data including the following information:

  • Name
  • E-Mail Address
  • Individually provided data, that you have given us in the pre-sign up   

We use this data to provide customer-oriented demographics for improving marketing strategies and products.

Hosting of our Website

Our Website is hosted by a third party service provider based in the US. To protect your privacy when transferring data we have concluded Standard Contractual Clauses provided by the Singaporean and Swiss commission. Furthermore, our hosting service provider is contractually bound to our instructions under a Data Processing Agreement. Additionally, this service provider is bound to our instructions by a data processing agreement.

Third Party Content

Occasionally, we may include third-party content on our site, such as videos from YouTube, Maps from Google Maps, RSS feeds or graphics from other websites, based on our legitimate interest to provide additional content on our Website, In order to display the content, the providers of this content perceive the IP address of the users. We have no influence on storage and further use of the IP address by the third providers.

Customer Support

Reviewing Process

We are using Trustpilot, as service from Trustpilot A/S, Pilesstraede 58, 5th floor, 1122 Copenhagen, Denmark. Trustpilot allows you to review our services and give us feedback. Trustpilot will process your e-mail address.

Further information can be found at Trustpilot’s privacy policy.

Cookies

For a part of our service it is necessary for us to store cookies on your end device. Cookies do not execute programs on your computer. Instead, the main purpose of cookies is to provide customisation features when using our services (the “Functional Cookies”).

We use our own Functional Cookies for:

  • Log-in identification
  • Load distribution
  • To remember your settings
  • To remember your cookie consent The processing of data collected via our cookies is based on our legitimate interest to provide you a convenient and individualised service on our website.

Performance and Marketing Analytics

To improve our Website we use data collected by cookies and similar technologies (e.g. web beacons) for the statistical collection and analysis of general usage patterns. We also use this data for advertising and marketing purposes and to show personalised ads to you on our Websites and other websites.

Data collected by these cookies (the “Analytics Cookies”) will be processed by us or third party service providers, based on your consent.

The data collected by Analytics Cookies usually includes

  • IP address of your device.
  • Date and time of the access
  • Cookie ID number
  • Device ID of mobile devices
  • Technical information on browser and operating system (the “Device Fingerprint”)

This data is only collected and stored in pseudonymous form and is never used to identify you individually or to draw conclusions other than on a general, aggregated level.

Opt-out of tracking and withdrawal of consent

You can withdraw your consent for cookie processing at any time by clicking on the link or contacting us via our email address provided above. Please keep in mind that withdrawal is only effective towards CryptoTresor Bank, therefore you may be tracked by other websites using the services listed below.

If you wish to disable tracking in general, you can always configure your browser to decline cookies, in which case we will not be able to process data in the above mentioned way. Alternatively you can prevent cookies on your device, using the services of Trustee and YourAdChoices.

 

II. Data Processing for the purposes of our Banking Platform

If you use our Banking Platform, CryptoTresor Bank will be considered Joint Controllers for any processing related to your use of the Platform.

1. Responsibility for Platform related requests and inquiries

As Joint Controllers CryptoTresor Bank is responsible for any Platform related requests and inquiries. Please address any privacy related matters to: dataprotect@cryptotresorbank.com.

2. Overview over data processing for our services

Our Platform provides you the opportunity to create and manage a bank account and a wallet, which allows you to easily connect your crypto funds to the fiat world. To perform these services, we need to process your personal data, including:

  • Banking Information (IBAN, BIC, transaction history, personal data)
  • Crypto Information (public keys, transaction history)
  • Trading Information (order information, transaction history)
  • Card Payment Data (transaction data, transaction history)
  • Account Information (Address Data, Contact Information, Identification Documentation, Tax Information)

3. Processing of data for your User Account

CryptoTresor Bank will be considered the responsible Joint Controller for processing of personal data for the provision of your User Account and will therefore handle any of your account related requests.

To use our Platform you need a User Account. For this reason we process your Account Information.

4. Processing of data for our Blockchain Interface

The CryptoTresor Bank will be considered the responsible Joint Controller for processing of personal data for the provision of our Blockchain Interface and will therefore handle any of your blockchain related requests.

Core feature of our banking services is a Blockchain Interface that allows you to interact with your Wallet and the respective Blockchain. While we have no control over the processing of personal data on the respective Blockchain, we are processing your data to create and manage the access to your wallet.

Wallet Creation

Your wallet will be provided by a third party service provider. For the creation process you have to generate a pair of keys which will be used to access your wallet. The original generation of the keys takes place exclusively on your own end device. At no point will CryptoTresor Bank have access to the funds in your wallet.

Please remember to save guard your keys with the appropriate measures and to always use strong password encryption. CryptoTresor Bank will not be able to help with lost access to wallets and/or lost funds. As the wallet provider is located in the USA, Crypto Information in will be transferred to the US upon any of your interactions with the wallet, including its creation.

Initiating and receiving transactions

Any incoming or outgoing transactions will be initiated on our Platform and sent via your Wallet to the respective Blockchain. Therefore, for each transaction, one of the addresses stored in your wallet will be published to the respective open public blockchain and be publicly available over the internet. While the transaction data may not seem to be personally identifiable information it is still considered personal data under SDPR as it is possible for us to match single addresses to our users for the provision of our services.

While we are not able to control any processing that happens on the Blockchain, we take industry standard precautions to ensure that your privacy is protected.

Transaction History

Our Platform provides you an overview over any transaction sent or received from both your wallet and bank account. To maintain an overview of your crypto transaction we keep a history of all incoming and outcoming transactions on your wallet.

Blockchain Security Aspects

Your digital assets are stored on the blockchain and can be accessed or transferred using the wallet. CryptoTresor Bank cannot cause transactions from your wallet except on your request. Any request issued via our Blockchain Interface to the wallet provider must be signed with a private key which is exclusively known to you and serves as you “wallet password”.

To further increase security, our Blockchain Interface is whitelisted with the wallet provider. Therefore, any interaction from another interface with your wallet will be blocked by default. If you wish, however, to transfer your wallet and make it accessible from third party interfaces, you may transfer your wallet by following the instructions in the CryptoTresor Bank Help Center.

5. Processing of data for our Banking Interface

CryptoTresor Bank will be considered the responsible Joint Controller for processing of personal data for the provision of our Banking Interface and will therefore handle any of your banking related requests.

6. Hosting of Web-Applications

CryptoTresor Bank PTE will be considered the responsible Controller for processing of personal data for the hosting of the applications that enable you to interact with your bank accounts and wallet and will therefore handle any of your requests related to the technical provision of the Banking and Blockchain Interface.

In addition to the data processed to provide the functionality of our Blockchain and Banking Interfaces, whenever you access our Platform via the Website, we will process the above mentioned technical data to establish the communication between your end-device and our applications.

Duration of storage

We store personal data only as long as necessary to fulfil our contractual or statutory duties. This means that, as long as your account is active, we will keep any data required to provide our Services. Upon your deletion of your account, we will delete any of your data, provided it is not required for purposes of evidence, in which case we keep it until expiration of statutory periods of limitation, or for statutory retention periods. 

In particular, CryptoTresor Bank may be subject to retention periods under Singaporean and Swiss Law up to 10 years for relevant information. This may include certain technical information related to the initiation or the receipt of payments.

Rights of the persons concerned

You have the right to information about the processing of your personal data at any time and free of charge. This information includes an overview of the data relating to you, as well as a copy of such data (Right to Access). Should data be or become inaccurate, we are obliged to correct the information on your request (Right to Rectification). You may at any time request the deletion of data (Right to Erasure). Wherever we are not able to delete your data, as may be the case when we are subject to statutory retention periods, data processing will be restricted. Processing will also be restricted upon your request, if you believe that the data we have stored are not correct or if there is a dispute over the legality of the processing (Right to Restriction of Processing). You may at any time request us to transfer your personal data to you or a third party of your choice (Right to Data Portability). You additionally have the right to lodge a complaint a complaint with a supervisory authority (Right to lodge a complaint).

For your convenience we have implemented a special data privacy team at CryptoTresor Bank which will handle and, where necessary, forward all requests, which can be reached at:

dataprotect@cryptotresorbank.com

Right to withdraw consent

You have the right to withdraw any consent you may have given to us at any time. In this case, data processing will no longer take place based on your consent. The withdrawal however does not affect the lawfulness of past processing activities. If you would like to withdraw any consent given to us, please contact either of the Joint Controllers using their contact details provided above or direct your request to:

dataprotect@cryptotresorbank.com

Alternatively you may use features provided within our applications to withdraw your consent.

Right to objection to processing based on legitimate interest

Wherever we process your data on the basis of legitimate interests, you have the right to object to the processing of your data.

You may at any time object to data processing for direct marketing purposes.

If you would like to object to any of our performance or marketing analytics purposes, please use one of the above listed opt-out methods or contact:

dataprotect@cryptotresorbank.com