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Legal HubPrivacy Policy

KNOW THE BASICS

We take your privacy seriously. This page explains what personal data we collect, why we collect it, how we use it, who we share it with, and what control you have over it.

1.

Who is the data controller?

2.

For what purposes and on what basis is Users’ personal data processed?

3.

Which Users’ personal data is being processed?

4.

With whom do we share your personal data?

5.

For how long will Users’ personal data be processed?

6.

Which security measures do we implement to protect Users’ personal data?

7.

How can Users exercise their rights?

8.

Changes to this Privacy Policy

Privacy Policy

Version 1.1.3 - September 24, 2024
FULL TEXT
SUMMARY

1. Who is the data controller?

The entity in charge of the collection and processing of your personal data is Venga Europe SL, with a registered office at Norrsken House, Passeig del Mare Nostrum 15, Ciutat Vella, 08039, Barcelona, and tax identification number B56395585. Venga’s responsible person in terms of data protection can be contacted here.

Who is the data controller? It´s us - Venga Europe SL. We’re the ones responsible for how your personal data is collected and used. You can contact us any time for privacy-related questions.

2. For what purposes and on what basis is Users’ personal data processed?

Users’ personal data will be collected and processed in the context of the Venga Services offered through the Venga Website, the Venga Platform, and/or the Venga Apps for the following purposes:

To execute, manage, and control Users’ contractual relationship in accordance with the Terms and Conditions of Use. The foregoing shall include, for illustrative purposes only: (a) the creation and management of a User account; (b) the provision and control of any Venga Services, including the processing of Users’ orders; (c) the provision of assistance with regards to any questions, disputes, complaints or inquiries that Users may submit in connection with the Venga Website, the Venga Platform, the Venga Apps or the Venga Services; or (d) the sending of any necessary communications regarding services and transactions related matters. The legal basis of the processing is either the application of pre-contractual measures (when the query is raised before contracting any Services) or the performance of the terms and conditions of use and the corresponding contractual relationship binding upon the User.

To respond to law enforcement requests, court orders, or governmental regulations, as well as in order to fulfill any legal obligations to which we are subject, including but not limited to legal obligations (e.g. KYC obligations) deriving from the applicable tax and anti-money laundering and terrorism financing laws (“AML regulations”). Please note that, indeed, most of the digital asset trading services that we provide are subject to strict and specific laws, regulations, and obligations. The legal basis in this case is complying with the applicable legal obligations.

To provide Users with promotions, including offers and other incentives that we may deem appropriate as rewards for using the Venga Services. The legal basis is our legitimate interest in rewarding and enhancing customer loyalty.

To promote the security and integrity of the Venga Services and, in this regard, to ensure the prevention and detection of fraud and credit risks and thus the security of our Users and the business. For the abovementioned purposes we may also assess and manage credit risks. The legal basis of the processing is our legitimate interest in ensuring the security of the Venga Services, the Users and of the company.

For the conduction of surveys regarding experiences using the Venga Website, the Venga Platform, the Venga Apps, and/or the Venga Services and in order to be able to develop, improve, and boost the Venga Services. The processing is necessary to satisfy the company’s legitimate interest in improving the Venga Services and the tools through which they are provided, as well as in enhancing User experience.

For any other business purpose stated when collecting Users’ personal data or as otherwise set forth in applicable laws.

Furthermore, and only with the consent of the User in each case, the User’s personal data would be processed for the following additional purposes:

In order to be able to recommend features and services that may be of Users’ interest, identifying their preferences and personalizing their experience within the Venga Services.

For the sending of advertising or commercial information, including by electronic means, about Venga digital asset trading and custody products and services that may be of interest to Users.

To manage Users’ participation in competitions and specific promotions.

We use your personal data to:

  • Create and manage your account.
  • Provide, operate, and improve our services.
  • Help with questions, disputes, and support requests.
  • Meet legal obligations (like anti-money laundering checks).
  • Keep the platform secure and prevent fraud.
  • Send you offers, rewards, and promotions (when allowed).
  • Improve the platform through surveys and feedback.

Some uses require your consent, like sending marketing emails or personalizing your experience.

3. Which Users’ personal data is being processed?

For the above mentioned purposes, the following categories of personal information will be processed:

Identification and contact information: including, in particular, name, surname, ID or passport number and relevant documents, date of birth, postal address, e-mail, telephone number, gender, nationality, ID credentials, password, and profile picture and image.

In certain instances, Users’ biometric data may also be processed (e.g., for identification purposes or as a chosen method of access to the Platform or the Apps) with Users' express consent or under any applicable law.

In the event that a User is a company or legal entity, certain information would be also processed in order for us to determine the final beneficiary of the corresponding account or trust account (such as corporate documentation, which might include personal data, the identity documents of the directors and major shareholders of the company as well as of the authorized signatory for the company's account, or the company’s business address and email address - which could correspond to those of an individual -).

Financial and payment information, including card and bank account details, trading activity, and information on transactions and, where applicable, source of funds, source of wealth, and information regarding trade sanctions lists.

Other personal information: any other personal information that might be needed or communicated as a consequence and/or for the provision of the Services, for instance, (a) personal data contained on User’s communications and request; (b) additional personal data (e.g. profession or professional sector, voice or additional identification data such as Social Security Number) that may be necessary for the formal identification of a User; or (c) information regarding Users’ communications with other users and the use they make of our Website, the Platform and the Apps, to the extent permitted by and in accordance with the legislation in force.

Communications. Communications with but not limited to our Customer Support, Product, and Marketing teams. Surveys responses and information gathered in the surveys in written form or in oral form.

Navigation information: Such as log data (e.g., access times, hardware, software information), usage information, browsing history, browser information, screen recording of service interaction and usage, location data (e.g., IP address, zip code), device identification, “cookie” information, page view statistics, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. For more information on our use of cookies, please visit our Cookies Policy.

Users may update the information held by us through the settings available in their account, or by reaching out to our Support team here. It should be borne in mind that in order for us to be able to adequately provide the Venga Services, Users are responsible for keeping their information up to date, and accordingly, undertake to regularly check the information provided to ensure it is accurate.

As established in the Terms and Conditions of Use, we do not knowingly collect or solicit personal data from individuals under eighteen (18) years old; if you are a child under eighteen (18), please do not attempt to register for or otherwise use the Venga Services or send us any personal data. If we learn we have collected personal data from a child under eighteen (18), we will delete that information as quickly as possible. If you believe that a child under eighteen (18) may have provided us with personal data, please contact us here.

We may collect:

  • Basic info – Name, ID, date of birth, address, email, phone, nationality, profile photo.
  • Extra ID checks – Biometric data (with consent), corporate documents for business accounts.
  • Financial info – Payment details, trading activity, source of funds.
  • Other info – Professional details, customer service chats, survey responses.
  • Navigation data – Log-ins, device info, IP address, cookies, browsing history. We don’t knowingly collect data from anyone under 18.

4. With whom do we share your personal data?

Users’ personal data will only be disclosed when so required by the applicable laws for defending our legitimate rights and interests and to business partners and service providers engaged in the provision of any ancillary services (e.g. providers of services such as data hosting or information technology and related infrastructure services). For the use of certain Services, and with the acceptance of the corresponding Terms and Conditions of Use, Users’ identification personal data that need to be processed in order to comply with the applicable AML regulations may be also communicated to other affiliates for the aforementioned purposes.

We may also share the User´s information with legal authorities (Courts, law enforcement authorities, regulators, attorneys, and other third parties) to comply with laws and legal obligations; to respond to law enforcement and regulatory requests; to comply with any forms of “travel rules” which require the transmission of User´s information to other financial institution, regulatory authorities or other industry partners; to investigate possible violation of our Terms and Conditions of use or other applicable Policy; to detect, prevent, investigate and report or to assist law enforcement in the investigation of suspected fraud or other illegal activity.

The abovementioned service providers, who might have access to personal data as a consequence of the provision of certain services, will be subject to the strictest duty of confidentiality through the relevant data processing agreements that will be executed. In the event that any of these service providers are located outside the European Economic Area and/or that, for any other reason, Users’ personal data needs to be internationally transferred, we undertake to perform the corresponding international data transfers only in accordance with the safeguards and requirements laid down in the applicable laws.

Likewise, Users’ personal data could be also communicated to third parties, for marketing purposes and/or for the provision of additional services and functionalities, whenever Users have granted their express consent to such communications.

We share it only when needed:

  • With service providers who help us run the platform (bound by confidentiality).
  • With legal/regulatory authorities when required by law.
  • For anti-money laundering checks with affiliates.
  • With third parties for marketing — but only with your consent.

Some data may be transferred outside the EEA, but only with legal safeguards.

5. For how long will Users’ personal data be processed?

Users’ personal data will be kept while they remain registered customers or users of the Venga Website, the Venga Platform, and/or the Venga Apps, and the personal data will be retained after the termination of the corresponding contractual relationship, duly blocked, for the time necessary to answer for any liabilities that may be derived from the relationship. For illustrative purposes only, personal data being processed in order to comply with anti-money laundering obligations should be kept after the termination of the contractual relationship for ten (10) years.

In some cases, personal data may be kept for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.

We keep your data while you’re a user and for a set time after you leave — for example, AML-related data must be stored for 10 years. Sometimes we keep it longer if the law requires it or to resolve disputes.

6. Which security measures do we implement to protect Users’ personal data?

We implement appropriate technical and organisational measures to maintain and guarantee confidentiality, integrity, and security of personal data. This includes encryption, access controls, regular audits, internal and external reviews, certifications, and contractual protections with providers.

We use technical and organisational measures to keep your data safe: encryption, access controls, regular audits, and industry-standard security practices.

7. How can Users exercise their rights?

Users may exercise their rights of access, rectification, deletion, opposition, restriction, portability, and withdrawal of consent by contacting [email protected]. Users must identify themselves and specify the right being exercised. Complaints can be submitted to the Spanish Data Protection Agency (www.aepd.es).

You can manage, move, or delete your data, and withdraw consent anytime. Contact us at [email protected] or complain to the Spanish Data Protection Agency (www.aepd.es).

8. Changes to this Privacy Policy

This Privacy Policy supersedes all previous Venga or Saptain applicable data protection policies to the extent they address the same issues and are not consistent with this Policy or impose less restrictive requirements.

We reserve the right to modify this Privacy Policy, as may be required from time to time as a consequence of the development of our business or the Venga Services or of any regulatory update. In the event that significant changes are implemented, we will duly notify users at their email addresses to offer all Users the option to review the changes and, if necessary, accept them before they take effect.

By continuing to use our services, you acknowledge and agree that any updates or changes to these Privacy policy will take effect immediately upon publication.

We may update this policy as our services or the law changes. For important updates, we’ll notify you before they take effect. By continuing to use Venga, you accept the updated policy.