Privacy policy

At NETZ (referred to as NETZ and its subsidiaries)1, we highly value your privacy and are committed to protecting it through this privacy policy ("Policy"). This Policy explains the types of information we may collect from you or that you provide ("Personal Information") through our "NETZ Pro" mobile application ("Mobile Application" or "Service") and any associated products and services (referred to as "Services"). Additionally, it describes how we collect, use, maintain, protect, and disclose this Personal Information. It also outlines the choices you have regarding the use of your Personal Information and how you can access and update it.

This Policy is a legally binding agreement between you ("User", "you", or "your") and NETZ (operating as "NETZ", "we", "us", or "our"). If you're accepting this Policy on behalf of a business or other legal entity, you confirm that you have the authority to bind that entity to this Policy. Consequently, the terms "User", "you", or "your" apply to such entities. If you don't have such authority or disagree with the terms of this Policy, you must reject it, which means you cannot access or use the Mobile Application and Services. By using the Mobile Application and Services, you acknowledge that you've read, understood, and agreed to follow the rules of this Policy.

It's important to note that this Policy doesn't cover the practices of companies we don't own or control, or individuals we don't employ or manage.

Automatic collection of information

When you utilize the Mobile Application, our servers automatically record data sent by your device. This data may encompass details such as your device’s IP address and location, device name and version, operating system type and version, language preferences, content searched within the Mobile Application, access times and dates, and other pertinent statistics.

The information collected automatically serves the sole purpose of identifying potential instances of misuse and compiling statistical data concerning the usage of the Mobile Application and Services. It's important to note that this statistical information is aggregated in a manner that does not permit the identification of any specific User within the system.

Collection of personal information

You can access and use the Mobile Application and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered in the Mobile Application, you may be asked to provide certain Personal Information (for example, your name and email address). 

We receive and store any information you knowingly provide to us when you create an account, make a purchase, or fill any forms in the Mobile Application. When required, this information may include the following:

  • Account details (such as user name, unique user ID, password, etc) 
  • Contact information (such as email address, phone number, etc) 
  • Basic personal information (such as name, country of residence, etc) 
  • Biometric information (such as facial recognition, fingerprints, etc) 
  • Proof of identity (such as a photocopy of a government ID) 
  • Payment information (such as credit card details, bank details, etc) 
  • Geolocation data of your device (such as latitude and longitude) 
  • Information about other individuals (such as your family members, friends, etc)

You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features in the Mobile Application. Users who are uncertain about what information is mandatory are welcome to contact us. 

Publicly-available blockchain data

When you connect your non-custodial blockchain wallet to the Services, we collect and log your publicly-available blockchain address to learn more about your use of the Services and to screen your wallet for any prior illicit activity. We screen your wallet using intelligence provided by leading blockchain analytics providers. Note that blockchain addresses are publicly-available data that are not created or assigned by us or any central party, and by themselves are not personally identifying.

Use and processing of collected information 

We serve as both a data controller and a data processor when handling Personal Information, unless a data processing agreement has been established with you, in which case you would be the data controller and we would be the data processor.

Our role may vary based on the specific context involving Personal Information. As a data controller, we collect your Personal Information necessary for accessing and utilizing the Mobile Application and Services, as we determine the purposes and methods of processing.

In situations where you provide Personal Information through the Mobile Application and Services, we act as a data processor. We do not own, control, or make decisions regarding the provided Personal Information, processing it solely according to your instructions, with you acting as the data controller.

To provide the Mobile Application and Services or fulfill legal obligations, we may collect and utilize specific Personal Information. Failure to provide requested information may result in the inability to offer requested products or services. Information collected from you may be utilized for:

  • Creating and managing user accounts
  • Managing and fulfilling orders
  • Delivering products or services
  • Enhancing products and services
  • Sending administrative information
  • Sending marketing and promotional communications
  • Providing product and service updates
  • Responding to inquiries and offering support
  • Requesting user feedback
  • Improving user experience
  • Posting customer testimonials
  • Enforcing terms, conditions, and policies
  • Protecting against abuse and malicious users
  • Responding to legal requests and preventing harm
  • Operating the Mobile Application and Services

The processing of your Personal Information depends on your interactions with the Mobile Application and Services, your location, and applicable legal requirements. Processing may occur based on:

  • Your consent for specific purposes
  • Necessity for performing this Policy and pre-contractual obligations
  • Compliance with legal obligations
  • Public interest or exercise of official authority
  • Pursuit of legitimate interests by us or a third party

We rely on user consent as the legal basis for collecting and processing your Personal Information. However, under certain legislations, processing may continue until objection without reliance on consent or other legal bases. We are available to clarify the specific legal basis for processing and whether providing Personal Information is a statutory, contractual requirement, or necessary to enter a contract.

Payment Processing and Security Measures

  • Payment Information Handling: Users may need to provide payment details for services requiring payment, such as credit card information. This information is solely used for processing payments.
  • Use of Payment Processors: Third-party payment processors are utilized to securely process payment information. These processors adhere to the latest security standards set by the PCI Security Standards Council.
  • Data Collection by Payment Processors: Payment processors may collect personal information from users to process payments, handle refunds, and manage payment-related queries. This may include email addresses, addresses, credit card details, and bank account numbers.
  • Storage of Financial Information: Financial information may be stored in encrypted form on secure servers of payment processors for future or recurring payments, subject to user consent.
  • Privacy Policies of Payment Processors: Users are advised to review the privacy policies of payment processors, as their use of personal information is governed by their respective policies, which may differ from the service's privacy policy.
  • Verification and Fraud Prevention: Users may be asked to permit the collection of data from third-party providers to verify identity, conduct credit checks, and prevent fraud or assess risk. This is done to ensure legal use of services, eligibility, and protection against fraud.

Managing information 

You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Mobile Application and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the 90 days duration, necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so simply by contacting us. 

Disclosure of information 

  • Sharing with Service Providers: Your information may be shared with third-party service providers who assist in the operation of the mobile application or service. These service providers are contractually bound to handle your information in a manner consistent with the operator's privacy policies. They are only authorized to use your information to perform specific services on behalf of the operator and are prohibited from using it for their own purposes.
  • Legal Obligations: The operator may disclose your information if required or permitted by law, such as in response to a subpoena or government request, to protect rights or safety, or to investigate fraud.
  • Business Transitions: If there is a business transition, such as a merger, acquisition, or sale of assets, your user account and personal information may be transferred to the acquiring entity as part of the assets.

Data Retention 

We will retain and utilize your Personal Information for the duration necessary to fulfill our legal obligations, as long as your user account remains active, to enforce our Policy, and to resolve disputes, unless a longer retention period is mandated or permissible by law. Following any updates or deletion of your Personal Information, we may utilize aggregated data derived from or incorporating your information, ensuring it cannot identify you personally.

Upon the expiration of the retention period, Personal Information will be securely deleted. Consequently, the rights to access, erasure, rectification, and data portability cannot be exercised after the retention period ends.

International Data Transfers and GDPR Compliance

Depending on your location, your data may be transferred and stored in countries other than your own, including the USA, UK, LATAM, and the Middle East. Any transfer of your Personal Information to countries outside the European Union will only occur if you have explicitly consented to it or if permitted under the GDPR and processed in your best interest.

You have the right to understand the legal basis for information transfers to countries outside the European Union or to international organizations governed by public international law, such as the UN, and the security measures implemented to protect your information. If such transfers occur, you can find more details in the relevant sections of this Policy or reach out to us using the contact information provided.

Please note that we are committed to ensuring the security of your personal data, adhering strictly to the guidelines outlined in our privacy notice, and complying with applicable legal requirements.

Rights of EU and EEA Residents under GDPR

If you are a resident of the European Union ("EU") or the European Economic Area ("EEA"), you have specific rights concerning your Personal Information under the General Data Protection Regulation (GDPR), which we adhere to as part of our commitment to your privacy. All terms in this section have the same meaning as defined in the GDPR unless otherwise stated.

  • Right to Withdraw Consent: You have the right to withdraw consent for the processing of your Personal Information at any time if consent is the legal basis for processing. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
  • Right to Access: You can learn if your Personal Information is being processed, obtain details about certain aspects of the processing, and receive a copy of your Personal Information undergoing processing.
  • Right to Rectification: You can verify the accuracy of your information and request updates or corrections. You may also ask us to complete incomplete Personal Information.
  • Right to Object to Processing: You can object to processing carried out on a legal basis other than consent. This includes processing for public interest, official authority, or legitimate interests, provided you provide a valid reason related to your situation.
  • Right to Restrict Processing: You have the right to restrict processing under certain circumstances, such as contested accuracy, unlawful processing, or pending verification of legitimate grounds.
  •  Right to Erasure: Under certain conditions, you can request the erasure of your Personal Information. Exclusions apply, such as when processing is necessary for legal compliance or freedom of expression.
  • Right to Data Portability: You have the right to receive your Personal Information in a structured, commonly used, and machine-readable format, and, if technically feasible, transmit it to another controller without hindrance.
  • Right to Lodge a Complaint: You can file a complaint with a data protection authority regarding our collection and use of your Personal Information. If unsatisfied with our response, you have the right to lodge a complaint with your local data protection authority in the EU or EEA.

These rights are applicable if your Personal Information is processed by automated means and based on your consent, contractual agreement, or pre-contractual obligations.

Rights of Residents under State Privacy Laws

If you reside in California or other states with specific privacy laws, you have certain rights regarding your Personal Information, and we are committed to facilitating your exercise of these rights in accordance with applicable laws. This supplemental section, along with other relevant sections of the Policy, outlines your rights and how to exercise them under various state laws, including the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and similar legislation in other states.

  • Right to Know and Access: You have the right to request information about the Personal Information we have collected about you. Upon receiving a verifiable request, we will disclose: 
  1. Specific pieces of Personal Information we hold about you
  2. Categories of sources from which your information is collected
  3. Purposes for collecting, selling, or sharing your Personal Information

You may also request the information to be provided in a portable and easily usable format if technically feasible.

  • Right to Correction: You can request correction of your inaccurate Personal Information, considering the nature of the information and its processing purposes.
  • Right to Deletion: You have the right to request deletion of your Personal Information.
  • Right to Opt-Out of Sale and Sharing: You can opt-out of the sale or sharing of your Personal Information for monetary or other valuable consideration.
  • Right to Consent or Limit Use of Sensitive Personal Information: You can consent to the use of your Sensitive Personal Information and direct us to restrict its use and disclosure, within legal boundaries and the scope of your consent.
  • Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights. We will not treat you differently, deny you goods or services, or provide a different quality of service based on your exercise of privacy rights.
  • Shine the Light: California residents with an established business relationship with us have the right to know how their personal information is disclosed for direct marketing purposes under California’s "Shine the Light" law or opt out of such practices.

To exercise your rights, contact us using the details provided below. Upon verifying your request, we will process it to the extent feasible within our capabilities.

Submitting Requests and Identity Verification

Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf. 

You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you. 

Utilization of Third-Party Analytics Technologies

Our Mobile Application and Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information. The information gathered is used to compile statistical reports on User activity such as how often Users visit our Mobile Application and Services, what pages they visit and for how long, etc. We use the information obtained from these analytics tools to monitor the performance and improve our Mobile Application and Services. We do not use third-party analytics tools to track or to collect any personally identifiable information of our Users and we will not associate any information gathered from the statistical reports with any individual User.

Protection of Children's Privacy

We are committed to protecting the privacy of children under the age of 18. Accordingly, we do not knowingly collect any Personal Information from individuals under this age. If you are under 18, please refrain from providing any Personal Information through our Mobile Application and Services.

If you have reason to believe that a child under 18 has provided Personal Information to us, please contact us immediately to request the deletion of such information from our records. We encourage parents and legal guardians to actively monitor their children's online activities and to educate them about the importance of not disclosing Personal Information without permission.

We urge all parents and legal guardians to take necessary precautions to ensure that children are aware and instructed not to disclose Personal Information online without proper authorization.

Push notifications 

We offer push notifications to which you may voluntarily subscribe at any time. To make sure push notifications reach the correct devices, we use a third-party push notifications provider who relies on a device token unique to your device which is issued by the operating system of your device. While it is possible to access a list of device tokens, they will not reveal your identity, your unique device ID, or your contact information to us or our third-party push notifications provider. We will maintain the information sent via email in accordance with applicable laws and regulations. If, at any time, you wish to stop receiving push notifications, simply adjust your device settings accordingly.

External Links Disclaimer and Privacy Practices Notice

The Mobile Application and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Mobile Application and Services and to read the privacy statements of each and every resource that may collect Personal Information.

Opt-In Agreement for Mobile Messaging Services 

By providing your mobile phone number to us, you are voluntarily opting in to the Program and you agree to receive recurring mobile messages from us at the mobile phone number associated with your opt-in, even if such number is registered on any state or federal “Do Not Call” list. You agree that any mobile phone number you provide to us is a valid mobile phone number of which you are the owner or authorized user. 

If you wish to unsubscribe from our email campaigns, please click on the Unsubscribe link at the bottom of any marketing email sent from us. If you wish to stop receiving text messages from us, reply STOP, QUIT, CANCEL, OPT-OUT, or UNSUBSCRIBE to any text message sent from us. For more information, see our Mobile Messaging Terms and Conditions available. 

Data Security and Privacy Measures

We implement stringent security measures to safeguard the information you provide, storing it on secure computer servers in a controlled environment to prevent unauthorized access, use, or disclosure. Our efforts include maintaining reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and disclosure of Personal Information under our control. However, it's important to note that while we strive to ensure the security of your Personal Information, the inherent limitations of the Internet may pose security and privacy risks beyond our control. 

We cannot guarantee the absolute security, integrity, or privacy of information exchanged between you and our Mobile Application and Services. Despite our best efforts, there is a possibility that such information may be intercepted or altered by third parties during transmission. 

The security of your Personal Information also relies on the security measures of the device you use and the protection of your login credentials. You are also responsible for all of your activity on the Services, including the security of your blockchain network addresses, cryptocurrency wallets, and their cryptographic keys. Therefore, we advise you to take appropriate precautions to safeguard this information.

Data breach 

If we detect any compromise to the security of our Mobile Application and Services or any unauthorized disclosure of Users’ Personal Information due to external activities such as security breaches or fraudulent acts, we reserve the right to take appropriate actions. These actions may include investigating the incident, reporting it, and cooperating with law enforcement authorities. If a data breach occurs, we will make reasonable attempts to inform affected individuals if we determine there is a reasonable risk of harm to them or if legal obligations mandate notification. Notification will be sent via mail.

Changes and amendments 

We hold the right to modify this Policy or its terms concerning the Mobile Application and Services at our discretion. Updates will be indicated by a revised date at the bottom of this page and a notification within the Mobile Application. Additionally, we may notify you through the contact details you've provided or by other means we deem appropriate. Any revised Policy becomes effective immediately upon posting unless stated otherwise. Your continued use of the Mobile Application and Services after the effective date constitutes consent to the changes. However, we will not use your Personal Information in a significantly different manner without your consent from what was stated at the time of collection.

Acceptance of the policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Mobile Application and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Mobile Application and Services.

Contacting us 

If you have any questions about this Policy or how we collect, use, or share your information, please contact us at [email protected]. Or you may use the following data subject request form to submit your request: Click here to submit request .

1. NETZ Subsidiaries operating as NETZ DMCC in Dubai UAE, NETZ GLOBAL SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ in Poland, NETZ USA LLC in the United States of America.