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Privacy Policy

Bleutrade Privacy Policy

Bleutrade Privacy Policy

Bleu Digital Enterprises Ltd (“Company”).

The terms “we,” “us,” and “our” are used interchangeably with the Company.

Terms, abbreviations, words in this Privacy Policy shall unless otherwise defined in this Privacy Policy have the same meaning as per Terms of Use.

This Privacy Policy outlines how the Company collects, uses, shares, stores, disposes and protects the user, customer and visitor (“Data Subject”) Personal Data obtained through Bleutrade and the Platform. The Company shall do its outmost to preserve and protect the privacy of the Data Subjects. The Policy shall further explain how the Company complies with the General Data Protection Regulations 2016/679 (“GDPR”), the Data Protection Act, Chapter 586, laws of Malta (“Act”) and Processing of Personal Data (Electronic Communications Sector) Subsidiary Regulations 586.01 of the laws of Malta within the European Union (EU) and European Economic Area (“EEA”).

By using the Bleutrade, the Data Subject is subject to the Terms. Please take time to read the Terms of Use and the Privacy Policy. We want you to understand the type of Personal Data we collect when you register to use the Bleutrade.

The information collected from the Data Subject may be stored, processed, transferred, used and disposed by the Company including but not limited to the information and/or data that can be used on its own or with other information to directly or indirectly, identify, collect, contract or locate a single person or to identify an individual in context.

Definitions

The following definitions including but not limited to “Controller”, “Data Subject” and “Personal Data” used in this Privacy Policy have the same meaning that have been incorporated from the GDPR.

Personal Data

The Company acts as a Controller in terms of the GDPR and shall comply with the GDPR principles as stipulated in Section 5 (2) of the GDPR wherein it is stated that ‘the Controller shall be responsible for and be able to demonstrate compliance with the GDPR principles relative to the personal data as outlined in Section 5 (1) of the GDPR’. The Personal Data shall be processed fairly and in a transparent manner and collected only for legitimate purposes. The Personal Data collected by the Company shall be accurate and up to date and shall not be retained for longer than necessary. The Personal Data collected shall be protected in appropriate ways.

The Company shall protect the Personal Data of the Data Subject. The Company shall not transfer the Personal Data outside the EEA, unless the appropriate level of protection is ensured.

Information the Company collects

Information provided to the Company by the Data Subject when signing up/registering on the Bleutrade, when using the Bleutrade and the Platform, when using the website, when corresponding via phone, email or other means of communications services. The information may include Personal Data such as name, address, e-mail, phone number, financial or credit card or digital wallet information, ID or Passport copy, date of birth, residential address or other data which can be used for personal identification purposes and required in terms of Anti-Money Laundering/Know Your Client (“AML/KYC”) Manual and that may be required to comply with applicable laws.

The following technical information shall be automatically collected by the Company, including the internet protocol (IP) address used to connect your computer to the Internet, the Data Subject log in/sign in information, information about browser plug-in type and versions, time zone settings, including the full Uniform Resources Locations (URL) and others. The information may also be automatically collected by the Company through cookies and tracking. The Data Subjects are being advised that if they wish to deny the use of cookies from the Platform on the computer’s hard drive they should take necessary measures within their web browsers security settings to block all cookies from the website.

The Company may also receive information from third parties including, but not limited to the Company’s partners, payment services, advertising networks, search information for the purpose of fulfilling the provision of services or in order to comply with legal requirements.

In case, the Data Subject activates a location-enabled device with the Platform, the Company may collect location data or use various means to determine the location.

Use of Information

We use the information collected to provide our services to the Data Subjects and to verify your identity in line with AML/KYC Manual. We use the IP address and unique identifiers stored in your device’s cookies to help us authenticate your identity and provide our service. Given our legal obligations and system requirements, we cannot provide you with services without the collection of the data like identification, contact information and transaction-related information.

Consent

Your Personal Data may be processed only if you have unambiguously and voluntarily have given your consent or, the processing is necessary for the performance of the services or for your use of the Bleutrade or for the compliance with legal obligations as arising in view of AML Regulations or for an obligations arising out of public interest except where such interest is overridden by an individual’s interest to protect the fundamental rights and freedoms that arise from the right of privacy.

Rectification

The Company shall upon the Data Subject’s request rectify, block or delete his Personal Data that has not been processed in terms of GDPR and Data Protection Act. The Company will do its utmost to keep the Data Subject’s information updated. The Data Subject shall be required to notify the Company within a reasonable time with any updates in relation to his Personal Data.

Right to be Forgotten

In terms with GDPR, a Data Subject has a right to request the Company to erase his Personal Data. The Company will take all necessary measures to comply with such request unless the Personal Data will have to be retained to comply with legal obligations or court orders.

Cross-Border Transfer of Personal Data

The transfer of the Data Subject’s data may be necessary in order to use the services of the Bleutrade. Since the internet operates in a global environment, the use of the internet to collect and process Personal Data necessarily involves the transmission of data on international or cross – border basis. By using the Platform, by communicating with us, you acknowledge and expressly consent to the Company’s processing and disclosure of your Personal Data in this way. By participating in this Platform, communicating with us and using our Bleutrade, you provide your express consent to the Company’s disclosure of your Personal Data to third-party intermediaries (if applicable).

Security

The Company protects information collected using physical, technical, and administrative security measures to reduce the risk of disclosures, unlawful processing, accidental loss, destructions, damage and unauthorised access. Should a security breach take place, the Company will use reasonable endeavours to try to fix it.

Data Retention

The Company will retain your Personal Data and/or of visitors of the Platform for a reasonable period of time or as long as a law requires.

Disposal of Personal Data

When the Company receives requests to dispose of Personal Data by the Data Subjects, the Company shall ensure that these requests are handled within a reasonable time. The Company shall keep logs of such requests. The Company shall endeavour to provide an adequate disposal mechanism in order to ensure that no Personal Data is leaked to third parties.

Company’s Response to Personal Data Breach

When the Company learns of a suspected or actual breach of Personal Data, the Company shall perform an internal investigation and take appropriate remedial measures in a timely manner. Where there is a suspicion that there has been a breach of Data Subject’s Personal Data, the Company will notify the relevant competent authority within 72 hours from when the Company learns of such breach.

Governing Law

The Company is incorporated in Malta and by using the Bleutrade and the Platform or providing the information to the Company, you consent of processing and transfer of information in terms of Maltese law.

Amendments to the Privacy Policy

The Company may update the Privacy Policy from time to time at its own discretion and in response to changing legal, technical and/or business development. The Data Subjects shall be informed accordingly with respect to the updated version of the Privacy Policy.

Validity

This Privacy Policy was updated on the 29 December 2018 and is effective from that date.

E-mail: [email protected]
Company address: 60-2, Melita Street, Valletta VLT 1122, Malta

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