2. Information we collect
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.
3. How we use your information
We use the information we collect in various ways, including to:
- Provide, operate, and maintain our website
- Improve, personalize, and expand our website
- Understand and analyze how you use our website
- Develop new products, services, features, and functionality
- Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
- Send you emails
- Find and prevent fraud
4. Log Files
Centi follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.
5. Advertising Partners Privacy Policies
Note that Centi has no access to or control over these cookies that are used by third-party advertisers.
6. Third Party Privacy Policies
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.
7. List of Cookies
8. CCPA Privacy Rights (Do Not Sell My Personal Information)
Under the CCPA, among other rights, California consumers have the right to:
Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
Request that a business delete any personal data about the consumer that a business has collected.
Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
9. GDPR Data Protection Rights
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
10. Children’s Information
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
Centi does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
Privacy Notice for Wallet Interface Services of Centi
Last updated: July 2021
1. Privacy Notice
Protecting your privacy and personality is important to us. This privacy notice sets out how Centi Ltd processes and protects personal data that you provide to us or that we collect from you when you use our app. It is not part of a contract and may be changed from time to time.
The references to the EU General Data Protection Regulation (GDPR) do not apply where our processing of your personal data is not subject to the GDPR. Feel free to contact us as indicated below if you wish to learn more.
Centi Ltd (also “we” and “us”) is the controller for the processing in relation with your use of our services.
2. The personal data we process
We process the following categories of data:
- User data: We are essentially an electronic cash payment enabler to the consumer and merchant alike. Neither the merchant nor we know the identity of the person who makes the payment unless a customer opts in for identification. If you do, you provide us with your name, username and e-mail address.
- Contract data: We process data related to our Agreement with you.
- Technical data: When you use the app, we collect information regarding the installation of the app, your approximate location (only city and country), the volume of data you upload and download, and information about your device such as device type, operating system, device ID, your mobile carrier and your time zone.
- Communication data: If you contact us, we will receive information about you such as your name, address, email address, phone number, the contents of the communication and attachments you may send, and any other information you may choose to provide. When we send you an email or contact you otherwise, we may also collect information about your interaction with information sent, for example when you open an email or if you click a link.
- Other data: We may process other data we collect and process in relation with your Agreement with us, for example data related to complaints, to the defense and enforcement of rights etc.
Please see our separate privacy notice at https://centi.ch/privacy-policy for data relating to our website.
You are not under a statutory or contractual requirement to share personal data with us. However, if you choose not to provide personal data to us we may not be able to enter into an agreement with you or communicate with you.
When you share data with us, it must be current and accurate. If you opt to include data relating to third parties please make sure you have the right to share and that these third parties are informed about our processing of their data.
3. The purposes for which we process data and legal basis
We collect and process personal data for the following purposes:
- Entering into and performing our Agreement with you;
- providing support;
- anonymized usage analyses;
- enforcing obligations and our rights and defending against claims;
- complying with laws and regulations; and
- if you opt in: Sending you notifications to keep you updated and deliver personalised news, offers and marketing for our products and services;
We process your personal data for the purposes set out above on the basis that our processing is required
- to enter into, perform and enforce our Agreement with you (article 6(1)(b) GDPR), in particular user data, contract data and communication data);
- for our legitimate interest, in particular the interest in improving the app, in improving their features and developing new features, in defending and enforcing third party rights, in conducting direct marketing and in providing support and in communicating with you (article 6(1)(f) GDPR), in particular user data, contract data, technical data and communication data, and generally aggregate, statistical data);
- for other purposes based on your separate consent (article 6(1)(a) and 9(2)(a) GDPR).
4. How we share your personal data
Your privacy is of utmost importance to us and we take both the privacy and security of your personal data very seriously. We share your personal data only to the extent necessary for us to provide our services well and efficiently and will never sell it to third parties.
We may share your personal data with our service providers (for example IT service providers). We may also share personal data with public authorities, law enforcement agencies or other third parties as required under applicable law to comply with legal request or process, to enforce our rights including investigation of any potential misconduct, to prevent, detect or otherwise address illegal activity, abuse or security or technical issues, and protect the property, rights or safety of us, our users, third parties or the public as required or permitted by law.
We always aim to achieve that your personal data is solely transferred to, and stored in, Switzerland and other countries in the European Economic Area (EEA). In the unlikely event that your personal data is transferred to, or stored in, countries outside Switzerland and the European Economic Area (EEA) (in particular the United States) whose data protection laws may not provide the same level of protection as European data protection laws do, we require the recipient to agree to data processing agreements, usually in accordance with the European Commission’s model contracts (Standard Contractual Clauses). If you would like further information or to request a copy of these contracts, which may be redacted to ensure confidentiality, please contact us as set out in Section 9.
5. How we keep your personal data secure
In order to prevent personal data from destruction, loss, alteration, unauthorized access or disclosure we apply appropriate technical and organizational measures, in particular encryption, record keeping, and pseudonymization (as reasonably possible). Note please that data transferred through networks may be accessible to third parties.
6. How long we keep your personal data
As a rule, we process and keep your personal data for as long as your relationship with us is active. If your relationship with us is deactivated your data will be erased or anonymized. We may process your personal data for a longer period in backup copies and as necessary to safeguard our legitimate interests for example in keeping evidence, to fulfil our legal obligations, and if this results from a decision of the public authorities.
Some data is automatically generated and kept temporarily in log files each time you use our website, for example the IP address, information about your internet service provider, information about your operating system, the date and time of access, and content accessed when visiting our website. This data is used to provide our website and ensure functionality, system security and stability, and enable the optimization of our website as well as for statistics.
We may also use similar technologies such as pixel tags, fingerprints and others to store data in your browser. Pixel tags are invisible images or code that are pulled from a server and transmit certain information to the server, for example of and when a website was visited. Fingerprints are pieces of information collected when you visit our website and can distinguish your device from others. Most browsers support other technologies for storing data in the browser, similar to cookies (e.g. “web storage”), which we may also use.
In some cases when you access our website you have an option to activate or deactivate certain categories of cookies. You can also set your browser to block certain cookies or similar technologies or delete existing cookies and data kept in the browser, and you can delete cookies and stored data at any time via the settings of your browser.
Cookies and similar technologies help us make your visits more enjoyable. We process data in this context for the purposes of providing the website and enhancing user experience, and some cookies and technologies help us provide website functionality. In addition, they ensure you do not have to repeat certain settings or data entered during a session. Cookies and similar technologies can also help us safeguard the security of our website, detect and correct errors and detect and prevent misuse.
8. Your rights
In relation with the processing of your personal data, you have the following rights:
- Access right: You have the right to request disclosure of the personal data we store and process. If you have any questions regarding processing you may at any time contact us at the contact details in Section 9.
- Rectification right: You have the right to request that we rectify incorrectly stored data. You also are entitled to have incomplete personal data completed.
- Erasure right: You have the right to ask us to erase your personal data. You may exercise this right, for example, if you consider that the personal data is no longer necessary for the purpose for which it was collected or if you withdraw your consent to processing. Note that we may not comply with an erasure request as authorized by applicable law.
- Right to restriction of processing: You have the right to request us to restrict processing operations on personal data, for example, if we no longer need the personal data but you require it for legal purposes.
- Right to have Personal Data transferred: You have the right to receive certain personal data in a structured, commonly used and machine-readable format and to request that we transfer the data to another controller. The right to transfer personal data to another controller is only available if this is technically possible.
- Right to lodge a complaint with the supervisory authority: If you intend to lodge a complaint about our processing of your personal data, you may at any time contact the relevant supervisory authority or lodge a formal complaint. In Switzerland, the supervisory authority can be contacted at edoeb.admin.ch.
- Right to withdraw consent: If processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent, and we may be required or permitted to continue processing some data based on other legal grounds.
9. Contact details
Im Schilf 4
Please note that we are not a controller for any Encrypted Wallet Copy you may use with Centi.
Please note that your rights set out above may be subject to conditions or restrictions under applicable data protection laws.
If you wish to exercise any rights described above or want to obtain more information about it, please contact us as set out above. We may need to request information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any other person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
July 2021 / Version 2