HOW WE COLLECT INFORMATION ABOUT YOU
When Users access Services, ITF collects information sent through the User’s computer, mobile phone, or other access device. This information may include User’s IP address, device information including, but not limited to, identifier, device name and type, operating system, location, mobile network information, and standard web log information, such as User’s browser type, traffic to and from the Site, and the pages User accessed on the Site. ITF does not intentionally collect information from or about any individual who is under 18 years old, or any User who is otherwise unable to legally enter into a binding contract.1
If User creates an account or uses the Services, ITF, or its affiliates and/or vendors acting on ITF’s behalf may collect the following types of information:
- Contact information – User’s name, address, phone, email, Skype ID, and other similar information, which may directly or indirectly identify User; and
- Financial information – the full bank account and routing numbers and/or credit card numbers that User links to its Account or inputs when User accesses the Services.
When User utilizes the Services, the Site, or the Bot, ITF collects information about User’s interactions with the Services, the Site, or the Bot, and/or User’s other activities on the Site, and ITF may continuously collect information about User’s computer, mobile device, or other access device for fraud prevention purposes, to monitor for possible breach of User’s Account, and to identify any malicious software or other activity that may harm ITF or its users.
Finally, ITF may collect additional information User may disclose to ITF’s customer support team.
When User accesses the Site or content, or uses the Bot or any of the Services, ITF or the companies that work with ITF may place small data files called cookies or pixel tags on User’s computer or other device. The purpose of the use of these technologies is to:
- Recognize User as an ITF customer;
- Customize ITF’s Services, content, and advertising;
- Measure promotional effectiveness; and
- Collect information about User’s computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.
ITF uses both session and persistent cookies when User accesses the Site or content. Session cookies expire and no longer have any effect when User logs out of its Account or closes its browser. Persistent cookies remain on User’s browser until User erases them or they expire.
ITF also uses Local Shared Objects, commonly referred to as “Flash Cookies,” to help ensure that User’s Account is not compromised, to spot irregularities in behavior to help prevent fraud, and to support ITF’s sites and services.2
ITF encodes its cookies so that only ITF and any necessary affiliates can interpret the information stored in them. User is free to decline ITF’s cookies if User’s browser or browser add-on permits, but doing so may interfere with User’s use of Services. The help section of most browsers or browser add-ons provides instructions on blocking, deleting, or disabling cookies.
HOW ITF PROTECTS AND STORES PERSONAL INFORMATION
ITF stores and processes User’s personal and transactional information, including certain payment information, where ITF facilities or its service providers are located, and ITF protects such information by maintaining physical, electronic, and procedural safeguards in compliance with applicable laws. ITF uses computer safeguards such as firewalls and data encryption, enforces physical access controls to its facilities and files, and only grants access to Personal Information to employees and/or independent contractors who require such information to fulfill their job responsibilities.
ITF stores its Users’ Personal Information securely for the duration of the Users’ association with ITF. ITF will retain Users’ Personal Information for a minimum of five (5) years or as necessary to comply with ITF’s legal obligations or to resolve disputes.
HOW ITF USES THE PERSONAL INFORMATION IT COLLECTS
ITF’s primary purpose for collecting Personal Information is to provide the User with a secure, smooth, efficient, and customized experience. ITF may use User’s Personal Information to:
- Provide ITF Services and customer support User requests;
- Process transactions and send notices about User’s transactions;
- Resolve disputes, collect fees, and troubleshoot problems;
- Prevent and investigate potentially prohibited or illegal activities, and/or violations of ITF’s posted user terms;
- Customize, measure, and improve ITF Services and the content and layout of ITF’s website and applications;
- Deliver targeted marketing, service update notices, and promotional offers based on User’s communication preferences; and
- Verify User’s identity by comparing User’s Personal Information against third-party databases.
ITF will not use User’s Personal Information for purposes other than those purposes disclosed to User herein, without User’s permission. From time to time ITF may request User’s permission to allow the Company to share User’s Personal Information with third parties. User may opt out of having User’s Personal Information shared with third parties, or from allowing ITF to use User’s Personal Information for any purpose that is incompatible with the purposes for which it was originally collected or subsequently obtained with User’s authorization. If User chooses to so limit the use of its Personal Information, certain features or ITF Services may not be available to User.
ITF WILL NEVER SELL OR RENT USER’S PERSONAL INFORMATION TO THIRD PARTIES.
Any communications ITF sends to User will either be related to User’s Account or will be related to the Services, the Site, or the Bot. In the event ITF sends any communication to User which is not related specifically to User’s Account, the Services, the Site, or the Bot, ITF will provide User with an “unsubscribe” mechanism through which User may opt out of receiving other similar messages in the future.
HOW PERSONAL INFORMATION IS SHARED WITH OTHER ITF USERS
If User uses its ITF Account to transfer Digital Currency in connection with the purchase or sale of goods or services, ITF or User may also provide the seller with User’s shipping address, name, and/or email to help complete the contemplated transaction with the seller. The seller is not allowed to use this information to market their services to User unless User has agreed to it. If an attempt to transfer Digital Currency to User’s seller fails or is later invalidated, ITF may also provide User’s seller with details of the unsuccessful transfer. To facilitate dispute resolutions, ITF may provide a buyer with the seller’s address so that goods can be returned to the seller.
In connection with a Digital Currency transfer between User and a third party, including merchants, a third party may share information about User with ITF, such as User’s email address or mobile phone number, which may be used to inform User that a transfer has been sent to or received from the third party. ITF may use this information in connection with such transfers to confirm that User is an ITF customer, that Digital Currency transfers are enabled, and/or to notify User that it has received Digital Currency. If User requests that ITF validate its status as an ITF customer with a third party, ITF will do so. User may also choose to send Digital Currency to or request Digital Currency from an email address. In such cases, User’s user name will be displayed in an email message notifying the user of the designated email address of User’s action. Please note that merchants User interacts with may have their own privacy policies, and ITF is not responsible for their operations, including, but not limited to, their practices related to processing and storing Personal Information.
If User authorizes one or more third-party applications to access its ITF account, then information User has provided to ITF may be shared with those third parties. Unless User provides further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate User’s transactions using ITF services.
HOW ITF SHARES PERSONAL INFORMATION WITH OTHER PARTIES
ITF may share User’s Personal Information with:
- Third party identity verification services in order to prevent fraud. This allows ITF to confirm User’s identity by comparing the information User provides ITF to public records and other third-party databases. These service providers may create derivative data based on User’s Personal Information that can be used solely in connection with provision of identity verification and fraud prevention services;
- Service providers under contract who help with parts of ITF’s business operations such as bill collection, marketing, and technology services. ITF’s contracts require these service providers to only use User’s information in connection with the services the service providers perform for ITF, and prohibit them from selling User’s information to anyone else;
- Companies or other entities that ITF plans to merge with or be acquired by. User will receive prior notice of any change in applicable policy;
- Companies or other entities that purchase ITF assets pursuant to a court-approved sale under bankruptcy law;
- Law enforcement, government officials, or other third parties when:
- ITF is compelled to do so by a subpoena, court order, or similar legal procedure; or
- ITF believes in good faith that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of ITF’s End User License Agreement; and
- Other third parties with User’s consent or direction to do so.
Before ITF shares User’s information with any third party that is not acting as an agent to perform tasks on behalf of and under the instructions of ITF, ITF will enter into a written agreement requiring that the third party to provide at least the same level of privacy protection as required hereunder.
If User establishes an Account indirectly on a third party website or via a third party application, any information that User enters on that website or application (and not directly on the ITF Site, Service, or Bot) will be shared with the owner of the third party website or application and User’s information may be subject to their privacy policies.
In general, ITF will notify User of material changes to this policy by updating the last updated date at the top of this page, and will provide User with explicit notice of material changes as required by law. ITF strongly recommends that User visit this page frequently to check for changes.
SPECIFIC CONSENT BY USERS IN THE EUROPEAN ECONOMIC AREA
If User is located in, or is a resident of, the European Economic Area (“EEA”), User specifically and voluntarily consents to the transfer of User’s Personal Data to ITF’s related entities and service providers in non-EEA jurisdictions, for the specific purposes of performing identity verification or checking, to enable ITF to prevent fraud and comply with ITF’s legal obligations.
User may revoke its consent to this section at any time by emailing ITF with the subject line “Revoke EEA data consent.”
SPECIFIC CONSENT BY USERS IN SINGAPORE
User may revoke its consent to this section at any time by emailing ITF with the subject line “Revoke Singapore data consent.”
HOW USER CAN ACCESS OR CHANGE USER’S PERSONAL INFORMATION
HOW USER CAN CONTACT ITF ABOUT PRIVACY QUESTIONS
If User as questions or concerns regarding this policy, User should first contact ITF through the Contact Us form on the ITF webpage, or write to ITF at Blockchain Technology Hub SRO, Křižíkova 213/44, Karlín, 18600 Praha 8, Czech Republic.
- 1 By use of the Services, Site, and/or Bot the User covenants that it is over the age of eighteen (18), and/or competent and has capacity to enter into binding contracts
- 22ITF does not warrant complete protection for Users’ Account’s. ITF takes reasonable steps to ensure Users’ and their Account’s security, but the User understands that the Account may become compromised in spite of such efforts at any time. By using the Site, the Services, the Bot or any other ITF product all Users specifically indemnifies and holds ITF harmless for any loss or ill effect of the use of same and specifically covenants and understands that ITF shall have no liability for ANY damages as a result of such use.