Thank you for your interest in Avencia Digital Ltd ("Avencia Digital"). We are committed to protecting and respecting your privacy. This document explains how we look after your personal data and make sure that we meet our legal obligations to you under applicable UK data protection rules and the General Data Protection Regulation (Regulation (EU) 2016/679) ("the GDPR").
This Privacy Notice ("Notice") describes how Avencia Digital collects, stores and uses personal information ("Personal Information") including information about its customers, contacts, suppliers and job applicants, as well as about visitors to the Avencia Digital website at www.avencia.digital ("our site").
In this Notice, we use the terms "we", "us", and "our" (and other similar terms) to refer to Avencia Digital, and "you" and "your" (and other similar terms) to refer to our customers, contacts, suppliers, job applicants and site visitors.
For data protection purposes, the data controller is Avencia Digital Ltd. of 30A Thornhill Road, London, United Kingdom N1 1HW.
(2) How to contact us
If you have any questions about how we collect, store, and use Personal Information, then please contact our Data Protection Officer. You can either write at the above address or e-mail to email@example.com.
If you have any questions about this Privacy Notice, you may also contact us by e-mail to firstname.lastname@example.org.
(3) Who we are and what we do?
Avencia Digital Ltd. is a UK company (company number 12090230) which has its registered office at 30A Thornhill Road, London, United Kingdom N1 1HW.
Avencia Digital provides cryptocurrency brokerage services for cryptoassets and works with individual customers, corporate customers and institutional clients pushing the frontier in the digital currency space, with a dedicated focus on cryptocurrency market liquidity.
www.avencia.digital ("the Website") is operated by Avencia Digital Ltd, which manages all the data on the website and owns the website.
Avencia Digital can be contacted by the following means:
If you have any queries about the way we use your personal data, please contact our Data Protection Officer, using the e-mail address: email@example.com or the telephone or postal details above.
(1) The Personal Information that we collect
Before we provide our services to you, we undertake checks for the purposes of preventing financial crime such as fraud and money laundering, and terrorist financing by means of verifying your identity and undertaking specific screening. These checks require us to process personal data about you.
Depending on how you engage with us, we will collect and process the following data about you:
(a) Information that you provide voluntarily
(b) Information that we collect automatically as part of our crypto exchange service or manually as part of our brokerage service provision
(2) How we use your Personal Information
Depending on how you engage with us, we will use your information for the following purposes:
(3) Your data protection rights
Your personal data is protected by legal rights. You have the following data protection rights, subject to certain exemptions and satisfying certain conditions:
You have the right to access the personal data we hold about you. Requests to access your personal data should be made in writing and sent by e-mail. If you wish, to access, correct, update or request deletion of your Personal Information, you can do so at any time by contacting us via e-mail to firstname.lastname@example.org.
You may ask us to delete your personal data in certain circumstances. It may not be possible for us to delete all of the personal data we hold about you where we have an ongoing relationship, however, please contact our Data Protection Officer who will be able to assist with your request.
For more information or to exercise your data protection rights, please contact us using the contact details above.
(4) Automated decisions
We use the personal data you provide to us to create a risk profile of our customer. This risk profile is considered as part of your service provision, and we may take decisions by automated means as part of KYC, screening and due diligence checks with the scope to verify your identity to prevent and detect crime and money-laundering.
As part of the processing of your personal data, where decisions may be made by automated means is being endorsed by manual intervention. This means we may automatically conduct checks and when the result turns that you pose a fraud or money laundering risk or if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous activity or pattern, or you appear to have deliberately hidden your true identity then we will have a look manually into the flagged activity or result and will manually decide to accept or refuse the business relationship and provide the services you have requested, or we may stop providing existing services to you consistent and in accordance with the legal requirements applicable to us.
(5) Who we share your Personal Information with
We may disclose your Personal Information with the following categories of recipients:
(6) Legal basis for processing Personal Information
We process your personal data on different bases, according to the reason for which you have provided your data to us. Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests, and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "How to contact us" heading above or e-mailing us at email@example.com.
(7) Do I have to provide you with my personal data? What happens if I don't?
You will need to provide us with certain information in order for us to consider your application, and if you are accepted as a customer, in order for us to meet our contractual obligations to each other. You have no obligation to agree to us giving your data, but in that instance, we won't be able to initiate a business relationship with you and provide our service, while in the instance when you are an existing customer, we will have to terminate the business relationship. However, to consider your application or in the instance when you are an existing customer, you do not have to provide personal data to us which is over and above that which we need in order to fulfil our obligations to each other and/or meet a legal requirement.
(8) Cookies and similar tracking technology
(9) International transfers of Personal Information
Avencia Digital does not transfer your Personal Information to business partners or service providers that are located in territories outside of the UK.
(10) How we look after your Personal Information
We have in place what we believe to be appropriate technical and organisational security measures to protect your Personal Information against unauthorised or unlawful use, and against accidental loss, damage, or destruction. We put in place strict confidentiality agreements (including appropriate data protection obligations) with our third-party service providers. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
If you or others on your behalf give us any Personal Information about another person, you take full responsibility for complying with any relevant data protection laws which apply to the provision of that information to us, and our use of it as explained in this Notice.
(11) Data retention and security
We understand that the privacy and security of your personal data are of great importance, and therefore we have implemented security policies, rules, and controls to protect your information.
We will only retain personal data for as long as is necessary. In accordance with our retention policy and applicable anti-money-laundering legislation, we will retain your personal data for a minimum of five years from the end of our business relationship with you. Our business relationship will be deemed to be at an end on the date upon which your account is closed. This will either be when all outstanding sums under the agreement have been cleared and settled.
We retain Personal Information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, compliance, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
(1) Cookies Statement
We use both session, and persistent cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These cookies are essential to provide You with services available through the website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Type: Persistent Cookies
Administered by: Us
Purpose: These cookies allow us to remember choices You make when You use the website, such as remembering your login details or language preference. The purpose of these cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the website.
(2) What if I have a complaint?
We work to high standards when it comes to processing your personal data. If you are unhappy about how your personal data has been used, please contact our Data Protection Officer (DPO):
Our DPO will acknowledge your complaint straightaway and will independently investigate and respond within 30 days. In the unlikely event that the DPO has not been able to fully address the raised issue and offer a response within the statutory timeframe, you may escalate the complaint to the Information Commissioner's Office (ICO), which regulates the processing of personal data.
Following the response provided if you remain unhappy, you have the right complaint to the ICO about the way we handle your data or respect your rights. However, we would appreciate raising your dissatisfaction with our Data Protection Officer first to give a chance looking into the matter and try to resolve the complaint to your satisfaction. By allowing our independent officer looking into your dissatisfaction might help you obtain both a quicker resolution to your complaint and an answer with the sought explanation, you might be looking for.
You may reach out to ICO by following means:
Additional information on raising a complaint, you may find on ICO's website by following this link https://ico.org.uk/your-data-matters/raising-concerns/
(3) Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical, or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on the website. You can see when this Privacy Notice was last updated by checking the "last updated" date displayed at the top of this Privacy Notice.