Bauhinia.ee (hereinafter, "Bauhinia", "we", "us" or "our"), we are committed to protecting and respecting your privacy.
We define "Personal Information" as information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example, your name, email address, username, contact details or any unique identifier such as an IP address, device ID or other online identifiers.
1 DATA CONTROLLER
Bauhinia.ee, a company which is registered in Estonia under company registry code 14397544.
2 COLLECTION OF PERSONAL INFORMATION
We collect the Personal Information you provide directly to us or which we generate when you Sign Up a Bauhinia account, perform any transactions on the Bauhinia Exchange Platform, or use other Bauhinia services or our Site. This may include the following data:
Full legal name;
Mailing address and Country of residence;
Date of birth;
Proof of identity (e.g. passport, government-issued identity card or driver’s license), the number of the document, date of issue and expiration, photographic identification, address etc.;
Proof of residence (e.g. household utility bill or local authority tax bill);
Transaction history; and
We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
We may automatically collect information about your computer when you access the Bauhinia Site or use Bauhinia services. This is statistical data about our users' browsing actions and patterns and will not be used to identify any individual unless that same individual. This may include the following data:
Where available your IP address;
Device information, Operating system, and browser types;
Website usage information
This information may be directly obtained by us or through third party services.
In some cases, we need to collect certain types of information for compliance with legal requirements relating to Money Laundering and Terrorist Financing Prevention Act, Know-Your-Customer obligations. If this information is not provided we may not be able to provide a service for you. Your Personal Information may also be processed if it is necessary on reasonable request by law enforcement or regulatory authority, body or agency or in the defense of legal claims. We will not delete Personal information, if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
3 USE OF PERSONAL INFORMATION
We will process your Personal Information only for the purposes of providing to you the services that you ask us to provide and to comply the legal obligations stemming from regulatory obligations that arise from providing you the services.
We may use your Personal Information for the following purposes:
To establish and maintain a responsible commercial relationship with you;
To enable you to complete transactions on the Platform;
To process applications for Bauhinia account services, including making decisions about whether to agree to approve any applications;
To notify you about changes to our services, changes to our terms and policies, and as part of our efforts to keep the Bauhinia Exchange services, safe and secure.
To respond to your customer service requests and support needs;
To analyze use of the Site;
To comply with our legal obligations;
To provide information to you about developments and new products, although only if you have specifically agreed to receive such information;
To conduct market research and get feedback from you (e.g. surveying your opinions and needs about the Site etc.) Unless consented, your data for this purpose would be anonymized.
When you use Bauhinia Exchange Services, we use a browser feature known as a "cookie", which are small text files that are placed on your computer by websites that you visit. Cookies are typically stored on your computer hard drive, widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Many major browsers are initially set to accept cookies by default. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie, but choosing to remove or disable our cookies may not be able to use some of the features available on the Site.
The information collected from cookies allows us to determine such things as which parts of our Site are most visited and difficulties our visitors may experience in accessing our Site. With this knowledge:
We can recognize you as a customer;
We can better customize our service contents to provide you with essential features by learning more about your interests and services collect information about your use of our services; and
We can improve the quality of your experience on the Site.
5 DISCLOSURE OF PERSONAL INFORMATION
There are certain circumstances where we may share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use trusted service providers and contractors. Other recipients/service providers include our affiliates, agents, IT specialists, database providers, backup and disaster recovery specialists, email providers. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function.
We may also share your information with certain other third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you. These include credit reference agencies, anti-fraud databases, screening agencies, and other partners we do business with.
In certain scenarios such as below, your Personal Information may be transferred to other third party organizations:
We may also share Users’ Personal Information with financial institutions, insurance companies or other companies in the case of a merger, divestiture, or other corporate re-organization and notify you of such sharing of your information to be able to exercise any of your rights where applicable.
We may also share Users' Personal Information with law enforcement or regulatory agencies, as may be required by law. We may not be able to inform you of such sharing of data due to legal restrictions.
6 YOUR RIGHTS
You have certain rights concerning your Personal Information.
You are entitled to access can be exercised in accordance with the relevant data protection legislation. Upon your written request, we will inform you of the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information. There may be a minimal charge for providing to cover administrative costs.
You are entitled to request by sending an email to us at firstname.lastname@example.org that any incomplete or inaccurate personal data we hold about you is corrected.
You are entitled to ask us to delete or destruct of both the Account and Personal Information in certain circumstances by sending an email to us at email@example.com. There are also certain exceptions where we may refuse a request for erasure, for example, where the Personal Information is required for compliance with the law and regulatory obligations or in connection with claims.
You are entitled to ask us to transfer certain of your personal data to another party if you no longer wish to use our services.
We may need to request specific information from you prior to assisting you in exercising any of your rights. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation.
If you refuse to prove your identity, we may decline to take actions in respect of your data, save restricting processing, until we can ensure that such actions are the rightful claim of the data subject.
We may use automated processing and profiling to reduce and prevent the risks of fraud, money laundering and abuse of our services. Through this automated processing, we carry out an analysis of your identification, transactional and behavioral patterns.
If you disagree with that automated processing to be carried out, we may not provide you with some or all our services.
We are committed to protecting to ensure the confidentiality of your Personal Information and to protect your Personal Information. Only people with a business need to know Personal Information, or whose duties reasonably require access to it, are granted access to your Personal Information. Such individuals will only process your Personal Information on our instructions and are subject to a duty of confidentiality.
The security measures will, from time to time, be reviewed in light of relevant legal and technical developments.
With you have consented to, or we are obliged to pass on Personal Information to third parties to provide you with a requested service or in the carrying out of a regulatory or legal obligation, we will request that the same levels of technical and organizational security measure be applied through contractual arrangements wherever possible.
We will notify you and any applicable regulator of a breach when we are legally required to do. Due to legal restrictions, we may not be able to inform you of such a notification.
In the event of a personal data breach or the failure of the measures of protection of such information, we will immediately notify you without undue delay.
8 THIRD-PARTY LINKS
It is your responsibility to review the privacy statements, policies, terms, and conditions of any person or company to whom you choose to link or with whom you choose to contract.
You agree that Bauhinia in no way responsible or liable for any of those third party sites, including, without limitation, any damages, losses, failures or problems caused by, related to or arising from those sites.
9 DATA RETENTION
We are required by law to store some of your Personal Information and transactional data beyond the closure of your account with us. Data stored for regulatory purposes only will be protected from unnecessary processing and will be held only for the purpose of being able to provide information or access to relevant authorities.
Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary.
Once we do not have any obligation to provide you with a service you requested, also no longer required by any relevant law or jurisdiction in which we operate, we will anonymize or dispose of your Personal Information in line with acceptable industry and security standards.
Our Site policies, content, information, promotions, disclosures, disclaimers, and features may be amended, revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of Bauhinia.
If we consider that your rights may be affected by any such changes, we will request you to confirm your consideration and acceptance prior to continuing our relationship with you.
11 PROTECTION OF MINORS
We do not intend to collect Personal Information from anyone under the age of 18 (hereinafter “Minors”).
If we learn that we have inadvertently gathered personal information from a Minor, we will take legally permissible measures to remove that information from our records and require the user to close his or her account and will not allow the use of Bauhinia services.
If you are under 18, do not enter any personal information on our Website.
12 CONTACT US
Last Updated | March 2019