Last Updated: 30 August 2022
CoinHub Privacy Policy
Privacy is of utmost importance at the CoinHub group of companies. We recognise the significance of protecting information which is stored on our servers or network or is intended to be stored on our servers or network and which relates to an individual. The data we protect are the “Personal Data” which is any information relating to an identified or identifiable natural person, sometimes called a data subject, and have made protecting the privacy and the confidentiality of Personal Data a fundamental component of the way we do business. This Privacy Policy informs you of the ways we work to ensure privacy and the confidentiality of Personal Data and describes the information we gather, how we use those Personal Data and the circumstances under which we disclose such information to third-parties.
This Privacy Policy is designed to address regulatory requirements of the jurisdictions in which CoinHub offers its Services, including the General Data Protection Regulation (“GDPR”), as enacted by the European Commission. In this Privacy Policy, the term “Service” and “Services” has the same meaning as described in the User Agreement, but excludes API services, which are governed by a separate agreement. If you do not agree with this Privacy Policy, in general, or any part of it, you should not use the Services. This Privacy Policy is periodically reviewed to ensure that any new obligations and changes to our business model are taken into consideration. We may amend this Privacy Policy at any time by posting an amended version on our website.
Contents
About CoinHub
Collection of Personal Data
Use of Personal Data
Security of Personal Data
Retention of Personal Data
Storage of Personal Data
Your Rights
Acceptance
Questions and Complaints
1. Information About CoinHub
Our Services are offered through one or more subsidiaries of NHATPHONG TECHNOLOGY COMPANY LIMITED. By using the Services, you understand that your Personal Data may be processed by one or more of those subsidiaries (each, a “Data Controller”):
You may contact our Data Protection Officer (“DPO”) by email at living.solutions.vn@gmail.com.
2. Collection of Personal Data
When you access or use the Services, we collect the following information:
Information you may provide to us: You may give us information about you by filling in forms on our website or through our app or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use the Services and when you report a problem with the website or with our app.
Information we collect about you: With regard to each of your visits to our website or our app we automatically collect the following information:
Device Information: We collect information about the device you use to access your account, including the hardware model, operating system and version, and unique deviWe ce identifiers, but this information is anonymised and not tied to any particular person.
Internet or network activity information
User identification code
Google Analytics
Identifier for advertising (Google Play services permission)
User payment info, Uses Google Play's Billing Library
Crash log data from your app. For example, the number of times your app has crashed, stack traces, or other information directly related to a crash.
Information about the performance of your app. For example: battery life, loading time, latency, framerate, or any technical diagnostics.
Information We Collect from Other Sources: We also receive information from other sources and combine that with the information we collect through our Services. For instance:
We use third-party services that may be co-branded as CoinHub but will do so with clear notice. Any third-party services may collect information as determined by their own privacy policies.
Advertising or analytics providers may provide us with anonymised information about you
3. Use of Personal Data
We will use your Personal Data, to:
Understand and strive to meet your needs and preferences in using our Services;
Develop new and enhance existing service and product offerings;
Manage and develop our business and operations;
Carry out any actions for which we have received your consent;
Prevent and investigate fraudulent or other criminal activity;
To address service requests and resolve user questions; and
Meet legal and regulatory requirements.
The identifier for the ad. And you can customize not to make it available on your device.
We also reserve the right to use aggregated Personal Data to understand how our users use our Services, provided that those data cannot identify any individual.
We also use third-party web analytics tools that help us understand how users engage with our website. These third-parties may use first-party cookies to track user interactions to collect information about how users use our website. This information is used to compile reports and to help us improve our website. The reports disclose website trends without identifying individual visitors. You can opt-out of such third-party analytic tools without affecting how you visit our site. For more information on opting-out, please contact living.solutions.vn@gmail.com.
We will process your Personal Data legally and fairly and not use it outside the purposes of which we have informed you, including selling it individually or in the aggregate for commercial use.
4. Security of Your Personal Data
We protect Personal Data with appropriate physical, technological and organisational safeguards and security measures. Your Personal Data comes to us via the internet which chooses its own routes and means, whereby information is conveyed from location to location. We audit our procedures and security measures regularly to ensure they are being properly administered and remain effective and appropriate. Every member of CoinHub is committed to our privacy policies and procedures to safeguard Personal Data. Our site has security measures in place to protect against the loss, misuse and unauthorised alteration of the information under our control. More specifically, our server uses TLS (Transport Layer Security) security protection by encrypting your Personal Data to prevent individuals from accessing such Personal Data as it travels over the internet.
5. Retention of Your Personal Data
Except where prohibited by law, this period may extend beyond the end of the particular relationship with us, but only for as long as we are bound to do so for the audit, regulatory or other accounting purposes. When Personal Data is no longer needed, we have procedures either to destroy, delete, erase or convert it to an anonymous form. If you have opted-out of receiving marketing communications, we will hold your details on our suppression list so that we know you do not want to receive these communications.
After you have terminated the use of our Services, we reserve the right to maintain your Personal Data as part of our standard back-up procedures in an aggregated format.
6. Storage of Personal Data
CoinHub stores your Personal Data at secure locations in the EU. CoinHub ensures that appropriate security standards are in place regarding the safeguarding, confidentiality, and security of Data.
The information that we collect from you will be transferred to, and stored in, destinations outside of your country and the European Economic Area ("EEA") as described below:
We may transfer your Personal Data outside the EEA and the UK to other company subsidiaries, service providers and business partners (i.e., Data Processors) who are engaged on our behalf. To the extent that we transfer your Personal Data outside of the EEA and UK, we will ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with the GDPR and the UK Data Protection Act 2018. If transfers of Personal Data are processed in the US, we may in some cases rely on applicable standard contractual clauses.
7. Your Rights
The rights that are available to you in relation to the Personal Data we hold about you are outlined below.
Rectification
It is important to us that your Personal Data is up-to-date. We will take all reasonable steps to make sure that your Personal Data remains accurate, complete and up-to-date. If the Personal Data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your Personal Data to others, we will let them know about the rectification where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your Personal Data so that you can contact them directly.
You may inform us at any time that your personal details have changed by emailing us at living.solutions.vn@gmail.com and we will change your Personal Data in accordance with your instructions. To proceed with such requests, in some cases we may need supporting documents from you as proof that we are required to keep for regulatory or other legal purposes.
Erasure
You can ask us to delete or remove your Personal Data in certain circumstances such as if we no longer need it, provided that we have no legal or regulatory obligation to retain that data. Such requests will be subject to any agreements that you have entered into with us, and to any retention limits, we are required to comply with in accordance with applicable laws and regulations. If we have disclosed your Personal Data to others, we will let them know about the erasure request where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your Personal Data so that you can contact them directly.
Processing restrictions
You can ask us to block or suppress the processing of your Personal Data in certain circumstances, such as, if you contest the accuracy of that Personal Data or object to us processing it. It will not stop us from storing your Personal Data. We will inform you before we decide not to agree with any requested restriction. If we have disclosed your Personal Data to others, we will let them know about the restriction of processing where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your Personal Data so that you can contact them directly.
Data portability
In certain circumstances, you might have the right to obtain Personal Data you have provided us with (in a structured, commonly used and machine-readable format) and to re-use it elsewhere or ask us to transfer this to a third party of your choice.
Automated decision-making and profiling
If we make a decision about you based solely on an automated process (e.g. through automatic profiling) that affects your ability to access our Services or has another significant effect on you, you can request not to be subject to such a decision unless we can demonstrate to you that such a decision is necessary for entering into, or the performance of, a contract between us. Even if a decision is necessary for entering into or performing a contract, you may contest the decision and require human intervention. We may not be able to offer our Services if we agree to such a request by terminating our relationship with you. You can exercise any of these rights by contacting us at living.solutions.vn@gmail.com.
8. Acceptance
By using the Services, you signify your agreement to this Privacy Policy. CoinHub reserves the right to change or amend this Privacy Policy at any time. If we make any material changes to this Privacy Policy, the revised Policy will be posted here and we will notify our users at least 30 days prior to the changes taking effect so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it. Please check this page frequently to see any updates or changes to this Privacy Policy.
9. Questions and Complaints
Any questions about this Privacy Policy, the collection, use and disclosure of Personal Data by CoinHub or access to your Personal Data as required by law (to be disclosed should be directed to living.solutions.vn@gmail.com.
In the event that you wish to make a complaint about how we process your Personal Data, please contact us in the first instance at In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at living.solutions.vn@gmail.com and we will attempt to handle your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the country in which you live or work where you think we have violated data protection laws.
California Residents
This section supplements the information in our main Privacy Policy and is intended to provide additional privacy disclosures as required under the California Consumer Privacy Act (“CCPA”) concerning the collection and disclosure of Personal Information (as defined in the CCPA of California residents in the preceding 12 months.
Categories of Information
In the preceding 12 months we have collected the following information:
Internet or network activity information
User identification code
Google Analytics
Identifier for advertising (Google Play services permission)
User payment info, Uses Google Play's Billing Library
Crash log data from your app. For example, the number of times your app has crashed, stack traces, or other information directly related to a crash.
Information about the performance of your app. For example: battery life, loading time, latency, framerate, or any technical diagnostics.
We may use this personal information for the following business purposes: (i) to operate, manage, and maintain our business, (ii) to provide our products and services, and (iii) to accomplish our business purposes and objectives, including, for example, using personal information to develop, improve, repair, and maintain our products and services and to fulfill your requests; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our property; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; to carry out corporate transactions,such as mergers, joint ventures or acquisitions; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
Your Rights
Pursuant to the CCPA, upon request and upon our verification of your identity, California residents may:
Request access to the specific and Personal Information that we have collected about you over the past twelve months, the categories of sources of that information, our business or commercial purposes for collecting the information, and the categories of third parties with whom the information was shared;
Obtain a copy of your Personal Information in a format that would permit you to transfer that Information to another Repository;
Submit a request for deletion of Personal Information, subject to certain exceptions, including (without limitation) in the event that we may need to retain Personal Information to complete the transaction for which the Personal Information was collected, detect security incidents, protect against illegal activity, exercise certain rights of free speech, comply with legal obligation or for internal uses permitted by law. If your request is subject to any exception, we may deny your request to delete your data. Please note that you must verify your identity and request before further action is taken by us. To do so, we will notify you of what we require via email.
To be free from unlawful discrimination for exercising your rights under the CCPA.
Do Not Sell My Personal Information
CoinHub does not sell Personal Information in the normal course of our business, but the CCPA defines sale more broadly than the traditional sense of an exchange of data for money and may encompass transactions in which we may share your Personal Information. Accordingly you may, subject to exceptions in CCPA, request that CoinHub not “sell” your Personal Information to the extent that we may do so. Please be aware that certain sharing of your Personal Information, such as disclosures of that Information to “Service Providers” as that term is defined and in accordance with CCPA, or for certain business operations of CoinHub, are not considered “sale” of Personal Information.
CCPA comprises provisions that explicitly prohibit us from making any adverse decisions about you or your account based upon your exercise of this right (“non-discrimination”).
The CCPA permits you to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.
To exercise any of the above rights, you may contact us at living.solutions.vn@gmail.com. Consistent with California law, you may designate an authorised agent to make a request on your behalf. In order to designate an authorised agent, please contact us via email living.solutions.vn@gmail.com. Please note that any proposed appointment is subject to verification checks and we may deny requests from agents who are unable to prove their identity or provide proof of authority to act on your behalf.
While many browsers permit you to send a signal about your Do Not Track (“DNT”) preferences, we do not respond to DNT signals sent from browsers.
Children’s Online Privacy Protection Act
CoinHub complies with the Children’s Online Privacy Protection Act COPPA, which requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13 years of age. CoinHub does not knowingly collect, use or disclose personal information from children under 13, or equivalent minimum age in the relevant jurisdiction, without verifiable parental consent. However, it is possible that we may inadvertently receive information pertaining to children under 13. If you believe that we have received information about your child that is under the age of 13, please do not hesitate to notify us at living.solutions.vn@gmail.com. When we receive your notification, we will obtain your consent to retain the information or will delete it permanently.
Vermont Privacy Rights (Applicable to Vermont Residents)
Vermont Financial Privacy Act
The Vermont Financial Privacy Act limits what we can do with your financial information and gives you rights to limit our sharing of your financial information. Under the Vermont Financial Privacy Act, Vermont residents have the right to receive notice and opt-in to sharing non-public Personal Information with non-affiliated third parties. Additionally, residents must consent to us sharing information regarding credit worthiness.
We do not share your information with affiliates and non-affiliated third parties, except for certain business purposes (e.g., to service your accounts), to market our products and services, as permitted by law, or with your consent. Additionally, we will not disclose credit information about you with our affiliates or non-affiliated third parties, except as required or permitted by law. You can access our Privacy Notice for information about our practices in accordance with the Vermont Financial Privacy Act. Please contact us to opt-in to, or opt-out of, sharing your non-public Personal Information.
Cayman Islands Data Protection Act
The Cayman Islands Data Protection Act (as amended, the "DPA") applies to CoinHub entities that are organised in the Cayman Islands, including CoinHub (Cayman) Limited. Where you engage the services of such an entity, that entity is a data controller with respect to your Personal Data and shall process your Personal Data in accordance with the requirements of the DPA. Subject to complying with the DPA, the entity may also share your Personal Data with its affiliates, its service providers and applicable regulatory and governmental authorities from time to time. Any transfer of your Personal Data outside of the Cayman Islands will be carried out in accordance with the DPA. Individuals have certain rights under the DPA with respect to their Personal Data, including the right to: (a) be informed about the purposes for which your Personal Data are processed; (b) access your Personal Data; (c) stop direct marketing; (d) restrict the processing of your Personal Data; (e) have incomplete or inaccurate Personal Data corrected; (f) ask us to stop processing your Personal Data; (g) be informed of a Personal Data breach (unless the breach is unlikely to be prejudicial to you); (h) complain to the Cayman Islands Data Protection Ombudsman; and (i) require us to delete your personal data in some limited circumstances.