Privacy Policy

These Privacy Policy were last updated on the 5th of September 2024

1. Preamble

This Personal Data Processing Policy (hereinafter referred to as the "Policy") applies to the relationship between Tracely (hereinafter referred to as the "Operator") and individuals (hereinafter referred
to as the "User" or "Users").

The Policy applies to information that the Operator receives about Users when they use the Website
and purchase services provided by the Operator.

The current version of the Policy is posted on the Website in the information and telecommunications network "Internet" at the address: https://tracely.io/privacy-policy

The Tracely service (also referred to as the "Company," "we," "us," "our") takes all necessary measures
to protect your privacy.

2. General Provisions

The Policy regulates the processing of personal data in the course of the Operator's business activities, including the provision of services for verifying the User's blockchain address or transaction for its compliance with AML/CTF requirements.

The security requirements for the personal data transferred between the Operator and the Data Subjects are provided for in the agreement concluded between them (User Agreement) in accordance with applicable law.

In cases where personal data is provided by the data subject, the latter is responsible for providing inaccurate personal data.

This Policy applies to personal data obtained both before and after this Policy comes into effect.

The Operator is required to adhere to the following principles when processing personal data:

- The processing of personal data must be carried out lawfully and fairly;
- The processing of personal data must be limited to achieving specific, pre-defined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed;
- Combining databases containing personal data processed for purposes incompatible with each other
is not allowed;
- Only personal data that meets the purposes of processing may be processed;
- The content and volume of the processed personal data must correspond to the declared purposes of processing. Processed personal data must not be excessive in relation to the declared purposes of processing;
- When processing personal data, the accuracy of personal data, their adequacy, and, where necessary, relevance to the purposes of processing must be ensured;
- Personal data should be stored in a form that allows for the identification of the data subject no longer than is necessary for the purposes of processing personal data, unless a longer storage period is required by federal law, a contract, or the data subject is a party, beneficiary, or guarantor under the contract. Personal data processed must be destroyed or anonymized upon the achievement of the purposes of processing or when the need to achieve these purposes no longer exists, unless otherwise provided by federal law.

3. Categories of Personal Data Subjects

The Operator processes personal data of the following categories of data subjects: data subjects who are Users of the site https://tracely.io.

4. Purposes and Grounds for Processing Personal Data

To the extent that we use personal data to fulfill contractual obligations or requests made by you
in connection with a contract, the legal basis for processing data is Article 6(1)(b) of the General Data Protection Regulation ("GDPR").

To the extent that we use personal data to comply with legal obligations under EU law or the law of an EU member state, the legal basis for processing data is Article 6(1)(c) of the GDPR.

The personal data of Subjects concerning the use of the Website is processed to achieve the following purposes:

- Introducing the User to the Operator's services;
- Concluding an agreement between the User and the Operator and for the purpose of fulfilling it;
- Notifying Users of changes in the Operator’s Service;
- Providing support and maintenance for Users of the Service;
- Monitoring the use of the Service;
- Issuing invoices and receiving payments from Users.

5. Categories of Processed Personal Data

The Operator has the right to process the following categories of personal data of the Subjects: name, age, passport details, bank card number, electronic payment system account number, cryptocurrency wallet address, email, phone number, address (home, street, city, country), cookies.

When the data subjects use the Operator's Website, the Operator processes data provided by international Internet data exchange protocols, including (but not limited to): IP address, MAC address, device ID, IMEI, MEID, Cookies, information about the browser, operating system, and access time.

Data related to your digital asset wallet, such as public keys, wallet balance, received and sent transactions.

Data collected in connection with compliance with Know Your Customer (KYC), Anti-Money Laundering (AML), and Counter-Terrorist Financing (CTF) requirements.

6. User Rights

The User has the right to:

- Request changes to the provided personal data, or their deletion;
- Submit inquiries to the Operator regarding the processing of their personal data by the Operator;
- Request changes to the provided personal data, or their deletion. Submit inquiries to the Operator regarding the processing of their personal data as it concerns the Operator;
- Exercise other rights provided by applicable law;
- You can exercise any of your rights concerning your Personal Data by contacting our Customer Support Service. Please note that before accessing or making changes to your Personal Data, we may need to verify your identity appropriately.

7. Operator's Rights and Obligations When Processing Personal Data

The Operator has the right to:

- Provide personal data to law enforcement agencies based on official requests;
- Provide anonymized statistical data to third parties for purposes consistent with this Policy.

The Operator undertakes to:

- Not use Users' personal data for purposes not provided for in this Policy;
- Disclose personal data to third parties without consent only in cases provided for by law and this Policy;
- Ensure the confidentiality of personal data to prevent unauthorized third-party access.

8. Final Provisions

The duration of personal data processing by the Operator may be determined by the Operator's organizational and administrative documents in accordance with personal data protection legislation.

This Policy may be amended or supplemented in the event of new legislative acts or specific regulations concerning the processing and protection of personal data, as well as by the Operator’s decision.

Compliance with the requirements of this Policy is controlled by the person responsible for organizing
the processing of personal data.

The Operator may issue other local acts clarifying specific principles of personal data processing.

If you have any questions about the Privacy Policy, please contact us at info@tracely.io.