Bittrex, Inc. Privacy Policy - Version 2

Effective Date: February 16, 2018

Bittrex, Inc. and its subsidiaries and affiliates (collectively, “Bittrex” or “we” or “us”) provide services that permit you to trade cryptographic tokens and other digital rights or assets. This Privacy Policy describes how Bittrex collects, uses, stores, and protects information about users of the Services and applies to information we collect when you use our website www.bittrex.com (the “Site”) and to any other related services provided by Bittrex (collectively, the “Services”). We may periodically post changes to this Privacy Policy by revising the date at the top of this page. We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Categories of Information Collected

Information You Provide to Us

We collect all the information you provide to us, such as when you register for an account on the Services (“Bittrex Account”), make deposits or withdrawals from your Bittrex Account, send fiat currency to us through the Services, apply for a job, sign up to receive our email updates, fill out a form, complete a survey, receive customer service, or when you otherwise communicate with us. This information includes, but is not limited to:

  • If you are an individual user: Your own personal data such as your first, middle, and last name, phone number, email address, photograph, physical address, date of birth, state and country of residency, username, password, social security number or other government ID number and photograph of government-issued identification information (including driver’s license and/or passport information).
  • Financial data such as full bank account information (including routing and account numbers) and certain digital currency information, including external wallet addresses.
  • Instructions you provide to us regarding your trades and other transactions you conduct through the Services;
  • Any feedback or suggestions you provide to us about our Services;
  • Information provided in any of Bittrex’s support channels or other communications channels; and
  • Any other information you provide to us or authorize us to access or collect from or using a third party.

In addition to the above, if you are using the Services on behalf of a corporation or other legal entity (“Enterprise User”), we collect and may retain all the information you provide to us, including all information provided in the Enterprise User’s application for a Bittrex Account. The information we collect from the Enterprise User’s application is described below:

  • Personal data of any individual who is identified as the person that controls the Bittrex Account and who is identified on the Enterprise User’s application for a Bittrex Account;
  • Basic entity information such as legal name, address, phone number, email address, tax ID number, state, and date of formation;
  • Information about the ownership and management of the Enterprise User such as a list of all beneficial owners, an organization chart, proof of identity for each individual beneficial owner that owns a 10% or greater interest in the Enterprise User, and proof of identity for each entity beneficial owner that owns a 10% or great interest in the Enterprise User;
  • Information about the Enterprise User’s legal existence such as entity charter (e.g. certificate of incorporation or articles of incorporation for a corporation, certificate of formation for a limited liability company, etc.) and certificate of good standing; and
  • Other documentation or information reasonably requested by us.

Information We Collect Automatically from our Services

When you use our Services, we automatically collect information about you as follows:

  • Transaction Information: We collect and store transaction details related to your use of our Services, including information about your Bittrex Account balances, trades, deposits, withdrawals, order activity, and any other transactions that you conduct or attempt to conduct through the Services.
  • Log Information: We collect standard server logs in connection with your use of our Services, that may include the type of browser you use, access times, pages viewed and IP address.
  • Device Information: We collect information about the computer or mobile device that you use to access our Services, including the hardware model, operating system and version, browser version, unique device identifiers and mobile network information.
  • Location Information: We may collect and use information to identify the location from which the services are being accessed in connection with providing the services.
  • Information Collected by Tracking Technologies: We may use various technologies to collect information in connection with your use of our Services. The technologies we use include the following:
    • Mobile device identifiers, which are used on mobile devices and perform functions similar to cookies and pixel tags; and
    • Cookies, which are small files that are sent to your computer or mobile device when you visit a website. Cookies allow our Services to recognize your browser and track your usage each time you visit. You can usually decline or remove cookies through your browser, but doing so may interfere with your use of Services; and
    • Local storage, which stores data locally in your browser, including user preferences; and
    • Pixel tags, which are small blocks of code often used in connection with cookies. Pixel tags (or web beacons) may be placed on our websites and emails, and allow us to track website usage, including to determine when emails have been opened and acted upon.

Information From Other Sources

We collect information from other affiliated and non-affiliated third parties and we may associate that with the information we collect about you. For example, in connection with your creation of a Bittrex Account or to enable your transactions, Bittrex may work with third party service providers to conduct identity verification and other screening procedures, including screening to verify that you are eligible to use the Services.

Security

While no online or electronic system is guaranteed to be secure, Bittrex takes reasonable measures designed to protect the information we collect from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. In particular, we implement reasonable security practices and procedures designed to protect the confidentiality and security of this information in accordance with, and prohibit disclosure other than as permitted by, this Privacy Policy. We also use reasonable measures designed to limit access to the information we collect about you to employees and agents that have a business reason to know such information.

Transfer of Information to the U.S. and Other Countries

While no online or electronic system is guaranteed to be secure, Bittrex takes reasonable measures designed to protect the information we collect from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. In particular, we implement reasonable security practices and procedures designed to protect the confidentiality and security of this information in accordance with, and prohibit disclosure other than as permitted by, this Privacy Policy. We also use reasonable measures designed to limit access to the information we collect about you to employees and agents that have a business reason to know such information.

Transfer of Information to the U.S. and Other Countries

Bittrex is based in the United States and the information we collect is governed by U.S. law. By accessing or using our Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law.

Our use of Personal Information

We may use information about you for various purposes, including to:

  • Provide, maintain, and improve the Services;
  • Adhere to our legal and compliance obligations, including our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations;
  • Provide and deliver the products and services you request, process transactions, and send you related information, including confirmations, receipts, and requests for authorizations,
  • Send you technical notices, updates, security alerts, and support and administrative messages;
  • Resolve disputes, troubleshoot problems, and provide customer service;
  • Communicate with you about products, services, offers, promotions, rewards, and events offered by Bittrex and others, and provide news and information we think will be of interest to you;
  • Prevent and investigate violations of our terms and protect the rights and property of Bittrex and others;
  • Measure, analyze and monitor trends, activities, and usage of the Services;
  • Conduct anti-fraud, identity verification, sanctions screening, and other screening procedures;
  • Personalize and improve the Services and provide advertisements, content, or features that match user profiles or interests;
  • Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
  • Link or combine with information we get from others to help understand your needs, provide you with better service, and facilitate our anti-fraud, identity verification, sanctions screening, and other screening procedures; and
  • Carry out any other purpose described to you at the time the information was collected.

Sharing of Personal Information

We may also disclose any information we collect with affiliated and non-affiliated third parties as follows or as otherwise described in this Privacy Policy:

  1. With service providers that perform services on our behalf, including identity verification services, sanctions screening services, fraud prevention services, and email marketing services. These service providers may create derivative data based on your personal information to conduct services on our behalf and may conduct their own searches of publicly available information about you in order to verify your identity or authenticate your information. You may in some cases provide information directly to those services providers acting on behalf of Bittrex, for example, to verify your identity before your Bittrex account can be fully enabled. You agree that any such service provider may share with Bittrex all information provided by you or created about you. ;
  2. To the extent required to complete transactions through your Bittrex Account e.g. with other Bittrex users with whom you are trading digital currency or with a financial institution that is sending or receiving fiat currency to or from your Bittrex Account on your behalf;
  3. With third parties for their own services and marketing purposes, unless you opt out of this type of sharing by sending an email to marketingoptout@bittrex.com;
  4. To comply with a legal request or to protect our rights or the rights of other Bittrex users, including:
    • To comply with an applicable law or regulation, or in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process;
    • To protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability; and
    • To protect the rights, property, and safety of Bittrex or others.
  5. In connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of Bittrex’s assets to another company;
  6. Between and among Bittrex and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
  7. With your consent, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

    We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Your Choices

Account Information

You may access and update your Bittrex Account profile information by logging into your Bittrex Account via our Services. When you close your Bittrex Account or otherwise cease your relationship with us, we may retain certain information as required by law or for our legitimate business purposes (like historical transaction information). We may also retain cached or archived copies of information about you for a certain period of time.

Promotional Communications

You may opt out of receiving promotional communications from Bittrex by following the instructions in those messages. Please note that if you opt out, we may still send you transactional or relationship messages, such as those about your Bittrex Account or our ongoing business relations.

Cookies and Local Storage

Most web browsers are set to accept cookies and local storage by default. If you prefer, you can usually choose to set your browser to remove browser cookies or clear local storage. Please note that if you choose to remove or reject these technologies, this could affect the availability and functionality of our Services.

Bittrex Affiliates and Contractors

An “Affiliate” is, with respect to a legal entity, another legal entity that controls, is under common control with, or is controlled by the first legal entity. The Site and any Services may be operated or provided by Bittrex, its Affiliates, or their respective contractors. To the extent that an Affiliate of Bittrex or contractor of Bittrex is operating or providing any Services, the Affiliate or contractor’s provision of such Services will be under terms identical to this Privacy Policy substituting the Affiliate or contractor’s name wherever Bittrex’s name occurs in this Privacy Policy.

Your California Privacy Rights

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. Under the law, a business must either provide this information or permit California residents to opt in to, or opt out of, this type of sharing. Bittrex qualifies for this alternative option. To opt out of having information about you shared with third parties for direct marketing purposes, please send an email to marketingoptout@bittrex.com.

Contact Us

If you have any questions about this Privacy Policy, please contact us at https://support.bittrex.com or at our address below:

Bittrex, Inc.
Seafirst Fifth Avenue Plaza
800 Fifth Ave
Suite 4100
Seattle, Washington 98104

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