Introduction to this privacy statement
This is the RICABOTS (“RicaBots”, “we”, “us” and “our”) Privacy Statement, and it applies to us while we process Personal Data belonging to individuals (“you”).
You share different types of personal data with us when you use the services provided by RICABOTS, create an account, visit our website and contact our support department.
In our Privacy Statement you can read how we treat your personal data. You will also find information about what personal data we process and what we do with it. Also, you can read about your privacy rights; for example, the right of access to information, the right of rectification and various forms of the right to object.
We update this Privacy Statement periodically to ensure that new obligations and technologies are taken into account, as well as any changes in our operations and business practices, as well as to stay ahead of the changing regulatory environment.
Purpose of this privacy statement
At RICABOTS we understand that your personal data is important to you. Through this Privacy Statement we intend to clearly explain what data we collect, why we collect it, how we use it, process it, store it and protect it.
The Privacy Statement applies to all RICABOTS customers, that is, to all persons who use, have used or have expressed a desire to use the services provided by RICABOTS.
How does BOTS obtain your personal data?
RICABOTS collects the personal data of its clients through:
- Direct interactions (such as when you register on the RICABOTS website or make a purchase);
- Third Party Data (such as information on third party websites or other information that Customers may have made publicly available, or information provided by third party sources such as government entities);
- Automated Tracking Technologies (such as automatically collected information about customer interaction with the BOTS website and application).
Why does RICABOTS collect your personal data?
RICABOTS collects Customer data based on its legal obligations under Art. 6(1)(c) of the GDPR: RICABOTS identifies all its Customers and obtains from them various sources of personal data, such as their name, date of birth, address and a copy of your identity document, in order to carry out customer due diligence and prevent fraudulent behavior or conduct that contravenes international sanctions and comply with regulations against money laundering, financing of terrorism and fraud fiscal.
RICABOTS also collects Client data on the basis of its performance obligation arising from the Agreement between RICABOTS and Client, in accordance with Art. 6(1)(b) GDPR: We collect information from you that is necessary for us to provide you with our services.
Any other data sources that are collected on the basis of the consent of the clients in accordance with Art. 6(1)(a) GDPR, which the Clients are free to give or refuse. By registering on the RICABOTS Platform, the Client agrees to the right of RICABOTS to store and process their data in accordance with the GDPR regulation.
What type of personal data does RICABOTS collect?
By registering on the RICABOTS website, Clients provide BOTS with (some of) the following data, which is stored and processed by RICABOTS.
The name and surnames as they appear in the passport;
Copy of passport or identity document;
Date and place of birth;
A visual image of the Client’s face with a handwritten note with the current date;
A visual image of the Client’s identity document;
The answers to a series of questions about the origin of the Client’s assets;
Additional information about the origin of the funds of the transactions;
A statement of the Client’s bank account to be used in connection with the BOTS services is your own personal bank account;
Payment to BOTS from an account opened in the Client’s name with a credit institution registered or with its registered office in an EEA Member State;
Additional documents, data or information that may be necessary to establish the identity of the Client and its verification.
Information that you are required to collect in connection with the “Know Your Customer” process (which may also contain information about possible fraud that has been committed).
- Number of your registration in the Chamber of Commerce;
- Statutory name;
- Legal form;
- registered address;
- Country of establishment;
- Regulatory and legal entity identifier (if applicable);
- Company situation;
- Identity of the UBO(s);
- Answer to a PEP verification question;
- Answer to a question about the origin of the funds and the area of activity;
- Organizational chart of the company up to the owners natural persons (UBO);
- Extract from the Chamber of Commerce;
- Copies of the passports of the UBO(s);
- Proof of the powers of attorney of the representatives;
- Additional documents, data or information that may be necessary to establish the identity of the Client and its verification.
In addition, BOTS stores and processes with respect to its customers, (some of) the following data:
- Fiat-cryptocurrency transfer history;
- business history;
- GPS location;
- IP adress;
- Bank account number/IBAN, BIC number;
- Your Customers’ Appstore/Google Playstore account information;
- Information about devices, operating system, online behavior and preferences data: such as the IP address of your mobile device or computer, the type, version and brand of the device used to visit the Bots App and bots.io, the operating system and the browser version you use, your cookie settings, your mobile advertising ID, and the pages you visit on the Bots App and bots.io.
- Data about your interests and needs that you share with us, for example when you contact our support team or address us in any way, such as through social media (Facebook, Twitter, Instagram, Google+ and YouTube). We track public messages, posts, likes, and replies to and about Bots on the Internet.
Your obligation to provide data
In some cases, we are required by law to collect personal data or your personal data may be necessary before we can perform certain services and provide certain products.
We undertake to request only the personal data strictly necessary for the corresponding purpose. Failure to provide the necessary personal data may cause delays in the availability of certain products and services.
What do we do with your personal data?
The personal information collected is used for the purposes for which the Clients have provided it, and may also be used for legal or other legitimate purposes only. RICABOTS uses the personal data of customers in the following ways:
- Manage the relationship with the Clients, such as providing and managing their access to and use of the RICABOTS Platform and the Website (this treatment is necessary for the execution of the Contract between RICABOTS and the Client);
- The improvement of RICABOTS services and the development of new products, such as the personalization of the Clients’ experience with the RICABOTS Platform (this processing is necessary for the legitimate interests of RICABOTS);
- Marketing, such as providing clients with marketing or advertising communications that RICABOTS deems relevant to them (this treatment is based on the consent given by clients and/or on the legitimate interests of RICABOTS);
- Provide online chat rooms, message boards and other communication channels to customers (this treatment is based on the consent given by customers and/or the legitimate interests of RICABOTS)
- Other general business support purposes, including but not limited to contracting, financial and tax management, risk management and regulatory compliance, and external reporting (this processing is necessary for compliance with a legal obligation to which RICABOTS and its exchange provider partners are subject, or that is otherwise lawful under applicable data protection laws or for the legitimate interests of RICABOTS).
With whom do we share your data and why?
In order to provide the best possible services and promote its business operations, RICABOTS may share certain Client data internally or with selected third parties incorporated within or outside the European Union. Some of these parties are incorporated in the United States. Parties with whom RICABOTS may share data include:
- Service providers; for example, for the management or hosting of the services and/or the technology to support the services provided by RICABOTS;
- Business partners; for example, cryptocurrency exchange provider partners (such as BANXA), payment service providers, etc.
- Other parties, for example, as necessary for external audit, compliance, risk management, corporate development, and/or corporate governance matters; or
- Government authorities and regulators, as required by applicable law.
Whenever we share your personal data with third parties in countries outside the European Economic Area (EEA), we ensure that the necessary safeguards are in place to protect it. For example, we rely, among others, on:
- Requirements based on applicable local laws and regulations;
- EU Model Clauses, where applicable, we use standard contractual clauses in agreements with service providers to ensure that the processing of personal data transferred outside the European Economic Area complies with the GDPR.
Your rights and how we respect them
As your personal data is processed, you also have privacy rights.
To the extent provided for in the GDPR, your rights include the following:
A) Right of access (“an overview of your personal information”): the right to obtain an overview of your personal information that we process.
B) Right of rectification (“correct your personal information”): If your personal information is inaccurate or incomplete, you have the right to ask us to rectify or complete your personal information.
C) Right of deletion (“right to be forgotten”): right to request that we delete your personal data to the extent permitted by applicable law.
D) Right to data portability (“port your personal information”): the right to ask us to transfer your personal information directly to you. This applies to certain personal information if it is processed by automated means and with the Client’s consent, or based on an agreement with RICABOTS.
E) Right to restrict treatment: right to request that we restrict or stop the treatment of your personal data that we have in our possession for a certain period of time, or for an indefinite period.
F) Right of opposition: right to oppose the processing of your personal data. The reasons for the objection must be related to your particular situation and to the treatment based on the condition of legitimate interest.
G) Withdrawal of consent: right to withdraw your consent for the processing of your personal data at any time; for example, after you have consented to be kept informed about our Services, you have the right to withdraw this consent at any time.
Customers can exercise the above rights by contacting RICABOTS Help Desk via email: firstname.lastname@example.org.
Our goal is to respond to your request as quickly as possible. In some cases, this can take up to a month (if allowed by law). If we need more time to complete your request, we will let you know how much time we need and explain the reasons for the delay.
How long do we keep your personal data?
The personal information of the clients will be processed to the extent necessary for the fulfillment of the obligations of RICABOTS, and for the time necessary to achieve the purposes for which the information is collected, in accordance with the data retention policies of RICABOTS and applicable data protection laws. When RICABOTS no longer needs your personal information, it will take all reasonable steps to delete it from our systems and records or take steps to properly anonymize it so that Clients can no longer be identified from it.
How do we protect your personal data?
We adopt the appropriate technical and organizational measures (policies and procedures, computer security, etc.) to guarantee the confidentiality and integrity of your personal data and the way in which it is processed. We apply an internal framework of policies and minimum standards in all our activity to maintain the security of your personal data. These policies and rules are updated periodically to keep them up to date with regulations and market developments.
In addition, RICABOTS limits access to personal information by our employees, business partners, service providers and third party service providers on a “need to know” basis. In addition, RICABOTS employees are bound by confidentiality obligations and may not unlawfully or unnecessarily disclose your personal data. To help us continue to protect your personal data, you should always contact RICABOTS if you suspect that your personal data may have been compromised.