Last revised: 31.10.2019
Counos OÜ (Commercial Register No. Est-14673576), domiciled at Laki tn 14a, 10621 Tallinn ("Counos OÜ"; “we”; “us”; “our”) collects two types of information about you resulting from your use of our websites;
(the “Site”) and/or our online trading platforms (and related services) in respect of virtual financial assets (the “Platform”):
- basic personal information, including your name and surname; and
- aggregate information which is generated from the practices that we have in place regarding ‘cookies’ and the Internet Protocol Address (“IP Address”) of the users of the Site and/or the Platform.
Please read the following carefully to understand how and why the Site and the Platform use your IP Address and cookies. If you do not accept or agree to the practices described in this Policy, you must exit both the Site as well as the Platform immediately. Continued use will be deemed to amount to your full acceptance and consent to the processing of the data set out above in sub-paragraphs (i) and (ii).
- IP Address
2.1 What happens when you visit the Site
Every time you connect to the internet or, if you use an always-on connection, such as broadband or DSL, when you boot up or restart your computer, you are automatically assigned a unique identifying number known as an IP Address. This IP Address, which contains information regarding the location of your computer on the internet (your country of origin) and the name of your internet service provider (“ISP”), is automatically logged by the Site.
The same also applies when you access the Platform via the Site or otherwise.
2.2 What is an IP Address?
When you first started your internet session (i.e. your computer connected to the internet), your computer was automatically assigned a unique number (normally in the region of 9 or 10 decimal numbers), known as an IP Address. This is your computer’s unique address on the internet. Without an IP Address, websites would not be able to deliver their content to you given that they would not be able find your computer on the internet. Since each time you disconnect and reconnect to the internet a new IP Address is automatically assigned to your computer, IP Addresses are not inherently capable of identifying you as an individual (at least, by themselves and not combined with other identifiers). An IP Address does, however, contain information regarding the location of your computer on the internet (your country), and the name of your ISP, and which when combined with other available information may lead to your identification. For these reasons, EU Data Protection Law (in particular, the General Data Protection Regulation (GDPR), Regulation (EU) 2016/679) treats IP Addresses as personal data with the resulting protections.
2.3 How do we collect your IP Address
Each time you visit a page on the Site or access the Platform, your computer sends out a message asking for the requested content to be delivered. This message sent by your computer also encloses your IP Address as a form of “return address”, so that the Site and/or the Platform may find your computer in order to send it that requested content. Our web-server automatically logs all these messages.
2.4 What do we do with your IP Address?
When we log your IP Address, the data collected is grouped up with the other logged IP Addresses in order to provide us with the statistics on the geographic location of visitors to the Site and/or the Platform, how long they stay on the Site and/or the Platform, which are the most viewed pages and for other statistical reasons that may be relevant for our business. We may also use your IP Address to confirm that you are eligible to access the Services and for other compliance related reasons.
We gather your IP address automatically and store it in log files. These files also contain information relating to your browser type, ISP, operating system, date/time stamp, clickstream data and the files viewed on Site and/or the Platform. Collecting this type of information allows us to generate aggregate information for the purposes of developing the Site and the Platform, including in terms of overall user trends and activities online (such as the number of unique visitors, pages accessed and viewed most frequently or the search terms entered). Furthermore, it also allows us to administer the Site and the Platform, diagnose any potential server problems, analyse visitor trends and statistics, and generally helps us to provide you with a better internet experience.
3.1 WHAT ARE COOKIES?
This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or 'break' certain elements of the Site’s functionality.
Cookies contain information that is transferred to your computer’s hard drive. A cookie enables the Site to remember users that have already visited. Without a cookie, every time you open a new web page, the server where that page is stored will treat you like a completely new visitor. Cookies allow us to remember your custom preferences such as your language preference and allow you to complete tasks without having to re-enter your information when browsing.
We may use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of the Site and the Platform. Namely, by way of illustration, they include cookies that enable you to log into secure areas of the Site and the Platform and make use of certain functionalities (e.g. log-in and access to your personal account and portfolio on the Platform).
- Analytical and Performance cookies. They allow us to recognize and count the number of visitors and see how visitors move around the Site and the Platform when using it. This helps us to improve the way and manner in which the Site and the Platform work, such as by ensuring that users are finding what they are looking in a seamless and straightforward manner.
- Functionality cookies. These are used to recognize you when your return to the Site and/or the Platform (as relevant). This enables us to personalize our content for you, greet you by name and remember your preferences set on the Site and/or the Platform (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to the Site and/or the Platform, the pages you have visited and the links you have followed. We will use this information to make the Site and the Platform, together with the advertising displayed on them, more relevant to your interests. We may also share this information with third parties for this purpose.
- Session cookies. These cookies contain encrypted information to allow our system to uniquely identify you while you are logged in. Session cookies exist only during an online session. They disappear from your computer when you close your browser software. These allow us to process your requests and help us make sure you are who you say you are after you have logged in.
The legal basis for the personal data processed by the way of cookies is article 6 para. 1 subpara. 1 lit. f of the GDPR.
3.3 DISABLING COOKIES?
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this).
Except for essential cookies, all cookies will expire after a set period of time.
Many browsers allow you to browse privately, whereby cookies are automatically erased after you visit a site. The following is a list of the most common browsers and the way in which you can activate private browsing:
- Internet Explorer 8 and later versions: In Private
- Safari 2 and later versions: Private Navigation/Browsing
- Firefox 3.5 and later versions: Private Navigation/Browsing
- Google Chrome 10 and later versions: Incognito
Further information on cookies can be found on various sites such as http://whatarecookies.com/
Social Media Features and Widgets
The Site includes social media features such as Twitter and Facebook links. These features may collect your IP address, which pages you are visiting on the Site, and may set a cookie to enable this feature to function properly.
Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
3.4 THIRD PARTY COOKIES
- OTHER INFORMATION STORED
4.1 Web Server Logs
For security and troubleshooting purposes our web server stores logs of activity on the website. The information stored includes: date, time, IP, page visited, result, amount of data sent and browser used.
4.2 Updates to this Policy
We will occasionally update this Policy to reflect changes in our practices and services. When we post changes to this Policy, we will revise the "Last Updated" date at the top of this Policy. We recommend that you check this page from time to time to inform yourself of any changes in this Policy or any of our other policies.
- MORE INFORMATION
If you need additional information please contact us per mail at email@example.com