Privacy Policy

Effective as of May 25, 2018

This Privacy Policy applies to the Amadeus website located at www.amadeusanalytics.com and describes how Amadeus collects and uses your personal data in the context of its website. For more information on our contact details see par. 12 “How to Contact Us”. We are committed to safeguarding your privacy. Therefore, we encourage you to read this policy carefully.

We have divided this privacy policy into different paragraphs. Please click on the relevant paragraphs below for further information.

1

Who We Are

We are Amadeus Analytics Ltd. Together with Amadeus Group Limited, we are responsible for the collection and use of your personal data described in this privacy policy. References to “Amadeus”, “we” and “our” throughout this privacy notice collectively refer to the aforementioned legal entities.

Amadeus powers cryptocurrency transaction analysis and monitoring on the blockchain, bringing best-in-class anti-money laundering compliance and risk management solutions to exchanges, banks, and financial institutions.

We have determined our respective responsibilities for compliance with our obligations under applicable privacy legislation for processing your personal data concerning our global processing activities through an arrangement between you and us. In summary, we have arranged that if you want to exercise your rights, such as your right to access, correct, erase, restrict, object or port personal data or to withdraw your consent, or if you have any questions about the processing of your personal data, you can contact us in accordance with par. 12 “How to Contact Us”.

Amadeus ensures that you can exercise your rights and that your questions will be handled within a reasonable time frame.

2

Types of Information Collected

When you visit our website to read or browse through website material or to download information, we may collect and process the following categories of personal data:

  • Name, address, e-mail address, company name, actions performed on our application website, and other contact information

You may choose to write to us or fill out certain forms for registration or online data requests, which provide the abovementioned information. We may use this information to respond to your questions and requests and to proceed with the registration for the application.

  • Our communication with you

When you send us an e-mail or otherwise communicate with us online (for example, via social media), we register your communication with us.

  • Information we collect when you use this website

When you use this website, certain information may be collected automatically, such as the name of the domain and host from which you access the Internet, the browser software and operating system of your computer, the Internet protocol (IP) address of your computer, and the Internet address of the site from which you linked directly to our site. We also collect information via cookies and similar technologies when you visit this website. For more information, please read our Cookie Policy.

  • Information about order processing

When you are a customer of ours, we also collect data for the purpose of order processing, pricing, and other information related to your order history.

We only use this information to register you on our application, to communicate with you, and for statistical research. We encourage you to review the privacy policy of the social media platform that you used to use to get more information about the processing of your personal data.

For specific services or software, we may collect other types of information and use such information for different purposes than described in this privacy policy. We inform you about this when you register for the specific service or download the specific software.

3

Collection of Information

We collect the mentioned above categories of personal data in the following ways:

  • We collect data you provide to us

When you communicate with us via e-mail, online or social media, when you place a purchase order, when you share personal preferences with us, we collect data directly from you.

  • Sometimes, companies we co-operate with also share your data with us

We provide certain services in co-operation with other companies (that our group of companies, which work together in processing your orders). These companies share your personal data with us if necessary for services provided to you. We also share your personal information with these third parties (please see par. 6 „Information Sharing“ below).

  • When you use our website, we collect information via cookies and similar technologies

For more information, please read our  Cookie Policy.

4

Use of Information Collected

The main purposes for which we use your personal information are:

  • To communicate with you

If you send us an e-mail or communicate with us online or via social media, we process your data to respond to you.

  • For statistical research

We use automatic tools (such as cookies) to perform statistical research into general trends regarding the use of this website and the behavior of the website’s visitors to improve this website.

  • For record-keeping and to comply with statutory obligations

We collect, store and use your data for internal business purposes, such as record keeping, and to comply with our legal and fiscal obligations.

  • To process your order

If you place an order on this website, we work on your data to process your order.

  • To improve the quality of our application

If you register on our application, we work on your data to improve our service.

5

We collect, use, and store your personal data to comply with the legal obligations we are subject to, if necessary for our legitimate interests or the interests of a third party, for the execution of an agreement, or on the basis of your consent.

If we process your personal data on the basis of your consent, you may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent, by adjusting your settings (if available), or by contacting us (please see par. 9 ‘Your Rights’ below).

When we process your personal data for our legitimate interests or the interests of a third party, we have balanced these interests against your legitimate interests. Where necessary we have taken appropriate measures to limit implications and prevent unwarranted harm to you. Our legitimate interests may, for example, include security and safety purposes, to improve this website, or to provide better products and offers to you. For more information on these interests, please see the purposes, for which we process your personal data above. More information on the balancing tests we perform is available upon request. Where we process your personal data for our legitimate interests or the third-party interests, you have the right to object at any time on grounds relating to your particular situation (please see par. 9 ‘Your Rights’ below).

Where we process your personal data for a purpose other than that for which we collected it initially (and we rely on a legal basis other than consent or complying with legal obligations for this new purpose), we will ascertain whether processing for this new purpose is compatible with the purpose for which the personal data were initially collected. More information on this assessment is available upon request (please see par. 9 ‘Your Rights’ below).

6

Information Sharing

Generally, we do not sell or share your personal data with anyone outside Amadeus and its affiliates. However, we do disclose or share data with the following categories of recipients for the following purposes:

  • For the support services we involve

We use third parties for support services to this website, such as IT suppliers (for example, SalesForce CRM system for processing your orders), social network providers, marketing agencies, credit and charge card companies, and anti-fraud screening service providers. All such third parties will be required to adequately safeguard your personal data and only process it by following our instructions.

  • Statistical research

For statistical research, we make use of third-party software such as Google Analytics or social media platforms. These platforms also have access to the data they collect. For example, when you accept cookies for this website, we analyze cookie data for statistical research via Google Analytics.

  • Group companies

When you use one of our services, it is possible that we share data with one of our group companies. For example, when you send us an e-mail about a subject that falls under the responsibility of one of our subsidiaries, we will forward your question to the correct subsidiary.

  • Ownership of Amadeus changes

If the ownership of Amadeus changes as a result of a merger, acquisition, transfer, sale of assets, reorganization, or bankruptcy your personal data may be transferred to the successor entity.

  • Public authorities

If we are required to by law, we also collect and share your identifying information with public authorities or governmental organizations.

  • Third-party websites

This website contains links to third-party websites; if you follow these links, you exit our website. While these third-party websites are selected with care, we cannot accept liability for the use of your personal data by these organizations. For more information, please consult the privacy statement of the website you are visiting (if such a statement is provided).

7

Security and Retention

Amadeus ensures that your personal data are properly secured by appropriate technical and organizational measures so that they are protected against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or wrongful destruction, and loss.

Your personal data will be retained for as long as required for the purposes described in this privacy policy or in so far as such is necessary for compliance with statutory obligations and for solving any disputes. For the retention period of the cookies used on this website, please see our Cookie Policy.

8

International Transfer of Your Data

Amadeus may transfer your personal data to countries other than your country of residence (including countries outside the European Economic Area). International transferring occurs in the course of providing your services or because our affiliates, partners, or service providers have operations in countries across the world. The laws of these countries may not afford the same level of protection to your personal data.

In the course of providing your services or because our group companies, partners, or service providers have operations in countries across the world, we may transfer your personal data to Georgia, China, Russia, the United Arab Emirates, Ukraine, the United Kingdom, and the United States of America.

The European Commission has determined that certain countries outside the European Union offer an adequate level of data protection (see article 45 General Data Protection Regulation (GDPR)).

Amadeus ensures that adequate safeguards are in place to comply with the requirements for the international transfer of personal data under applicable privacy laws. For transfers of personal data outside the European Economic Area, Amadeus may use European Commission-approved Standard Contractual Clauses as safeguards (see article 46 General Data Protection Regulation (GDPR)). Contact us to obtain a copy.

9

Your Rights

You may contact us (please see par. 12 ‘How to Contact Us’ below) to exercise any of the rights you are granted under applicable data protection laws, which includes (1) the right to access your data, (2) to rectify them, (3) to erase them, (4) to restrict the processing of your data, (5) the right to data portability and (6) the right to object to processing.

  • Right to access

You may ask us whether or not we process any of your personal data and, if so, receive access to that data in the form of a copy. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal data concerned as well as any other information necessary for you to exercise the essence of this right.

  • Right to rectification

You have the right to have your data rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, complete incomplete personal data, which may include the provision of a supplementary statement.

  • Right to erasure

You also have the right to have your personal data erased, which means the deletion of your data by us and, where possible, by any other controller to whom your data has previously been made public by us. Erasure of your personal data only finds a place in certain cases, prescribed by law and listed under article 17 of the General Data Protection Regulation (GDPR). Certain cases include situations where your personal data are no longer necessary in relation to the initial purposes for which they were processed as well as situations where they were processed unlawfully. Due to the way we maintain certain services, it may take some time before backup copies are erased.

  • Right to restriction of processing

You have the right to obtain the restriction of the processing of your personal data, which means that we suspend the processing of your data for a certain period of time. Circumstances that may give rise to this right include situations where the accuracy of your personal data was contested but some time is needed for us to verify their (in)accuracy. This right does not prevent us from continue storing your personal data. We will inform you before the restriction is lifted.

  • Right to data portability

Your right to data portability entails that you may request us to provide you with your personal data in a structured, commonly used, and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible, we will transmit your personal data directly to the other controller.

  • Right to object

You also have the right to object to the processing of your personal data, which means you may request us to no longer process your personal data. This only applies in case the ‘legitimate interests’ ground constitutes the legal basis for processing (see par. 5 “Legal Basis” above).

At any time and free of charge you can object to direct marketing purposes in case your personal data are processed for such purposes, which includes profiling purposes to the extent that it is related to such direct marketing. In case you exercise this right, we will no longer process your personal data for such purposes.

You may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent, by adjusting your settings (if available), or by contacting us (please see par. 12 ‘How to Contact Us’).

For more information on how you can withdraw your consent for cookies and similar technologies we use when you visit our websites, please check our  Cookie Policy.

Under conditions, we are entitled to deny or restrict your rights as described above. In any case, we will carefully assess whether such an exemption applies and inform you accordingly.

We may, for example, deny your request for access when necessary to protect the rights and freedoms of other individuals or refuse to delete your personal data in case the processing of such data is necessary for compliance with legal obligations. The right to data portability, for example, does not apply in case the personal data was not provided by you or if we process the data not on the basis of your consent or for the performance of a contract.

When you would like to exercise your rights, all you have to do is send your request to us using the contact details stated below (please see par. 12 “How to Contact Us”).

You can also contact us if you have any questions, remarks, or complaints in relation to this privacy policy.

10

Changes to Privacy Policy

This privacy policy was most recently amended on the effective date indicated in the upper left corner above and replaces earlier versions. We may update and/or change the terms of our privacy policy, and we will post any substantive changes on our website and provide them to you by e-mail prior to these changes taking effect, so that our users and/or visitors are aware of the type of information we collect, how it will be used, and under what circumstances if any, we may disclose such information.

11

This website uses cookies to personalize content, to provide social media features and to analyze our traffic. We also share information about your use of website with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. By clicking “Allow all cookies”, you agree with the use of cookies that are selected via the checked in boxes of the "Show details" menu. Declining cookies may affect your experience on our website.

We, Amadeus Analytics Ltd. (“Amadeus”), together with Amadeus Group Limited, store cookies and JavaScript (“cookies”) on your device when you visit our website amadeusanalytics.com. The next time you visit our website, cookies ensure that your device is recognized. The law states that we can store cookies on your device if they are strictly necessary for the operation of this website. For all other types of cookies, we need your permission. This website uses different types of cookies. Some cookies are placed by third party services that appear on our pages. You can at any time change or withdraw your consent from the Cookie Policy page on our website. Also learn more about who we are, how you can contact us and how we process personal data.

Your consent applies to our domains.

12

How to Contact Us

If you have any questions or concerns regarding the Privacy Policy related to our website, please feel free to contact us at:

Email:

privacy@amadeusanalytics.com