Privacy Policy
CTS Services Group LTD., CryptoTools Platform
Last updated: 3/05/2023
Introduction
CTS Services Group LTD. (“CTS Services Group”, “we”, “us”, or “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and disclose your personal information when you access and use the CryptoTools Platform, which provides free memberships for learning about cryptocurrency and blockchain, a cryptocurrency exchange, and for Premium Members who pay a subscription, an AI-based trading indicator and bot (collectively, the “Services”).
By using our Services, you agree to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Services.
1. Personal Information We Collect
Personal information typically means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that relates to, describes, is reasonably capable of being associated with or could reasonably be linked to an identified or reasonably identifiable individual. For the purposes of this Privacy Policy, only the definition of personal information from the applicable law of your legal residence will apply to you and be deemed your “Personal Information.”
CTS Services Group LTD., operating the CryptoTools Platform, may collect the following categories of Personal Information directly from you:
1.1 Personal Information we collect from you
Identification Information, such as name, email, phone number, postal address, government-issued identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number) and/or government-issued identity documents;
Commercial Information, such as trading activity, order activity, deposits, withdrawals, account balances;
Financial Information, such as bank account information, routing number;
Correspondence, such as information that you provide to us in correspondence, including account opening and customer support;
Employment Information, such as job title, source of wealth;
Membership Information, such as free or Premium Member status and payment information for Premium Members;
Usage Data, such as system activity, internal and external information related to CryptoTools pages that you visit, clickstream information, and interactions with our AI-based trading indicator and bot.
1.2 Personal Information we collect automatically
We may collect the following categories of Personal Information automatically through your use of our services:
Online Identifiers, such as IP address, domain name;
Device Information, such as hardware, operating system, browser;
Usage Data, such as system activity, internal and external information related to CryptoTools pages that you visit, clickstream information, and interactions with our AI-based trading indicator and bot.
Our automatic collection of Personal Information may involve the use of Cookies, described in greater detail below.
1.3 Personal Information we collect from third parties
We may collect and/or verify the following categories of Personal Information about you from Third Parties:
Identification Information, such as name, email, phone number, postal address, government identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number);
Financial Information, such as bank account information, routing number;
Credit and Fraud Information, such as credit investigation, credit eligibility, identity or account verification, fraud detection, or as may otherwise be required by applicable law; and
Additional Information, as permitted by law or required to comply with legal obligations, which may include criminal records or alleged criminal activity or information about any person or corporation with whom you have had, currently have, or may have a financial relationship.
Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned.
2. How We Use Your Personal Information
The Personal Information we collect and the practices described above are done in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve the CryptoTools Platform. We may use your Personal Information to:
2.1 Provide you with our services. We use your Personal Information to provide you with our services pursuant to the terms of our User Agreement. For example, in order to facilitate fiat transfers into and out of your account, we need to know your financial information. Additionally, we use your Personal Information to provide the AI-based trading indicator and bot to Premium Members.
2.2 Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations.
2.3 Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
2.4 Protect the security and integrity of our services. We use your Personal Information to further our security-first mentality. Maintaining the security of your account and the CryptoTools Platform requires us to process your Personal Information, including information about your device and your activity on the Platform, and other relevant information.
2.5 Provide you with customer support. We process your Personal Information anytime that you reach out to our Customer Support team, such as when there are issues arising from your account.
2.6 Optimize and enhance our services. We use your Personal Information to understand how our products and Services are being used to help us improve our Services, develop new products, and enhance the user experience.
2.7 Market our products to you. We may contact you with information about our products and services that we believe may be of interest to you. You may use tools that we provide to opt out of marketing communications from us at any time.
2.8 With your consent. We may use your Personal Information for additional purposes with your consent.
2.9 Other business purposes. We may use your Personal Information for additional purposes in the operation of our business, that would be reasonably expected based on context, and as permitted by law or required to comply with our legal obligations.
3. How We Share Your Personal Information
We will not share your Personal Information with third parties, except as described below:
3.1 Service Providers. We may share your Personal Information with third-party service providers for business or commercial purposes. Your Personal Information may be shared so that they can provide us with services, including identity verification, fraud detection and prevention, credit verification, security threat detection, payment processing, customer support, data analytics, Information Technology, advertising, marketing, data processing, network infrastructure, storage, transaction monitoring, and tax reporting. We share your Personal Information with these service providers only so that they can provide us with services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose. Our third-party service providers are subject to strict confidentiality obligations.
3.2 Affiliates. We may share your Personal Information with our affiliates, for the purposes outlined above, and as it is necessary to provide you with our Services.
3.3 Legal Obligations. We may be required to share your Personal Information with law enforcement, government agencies, regulators, or third parties to comply with legal or regulatory requirements.
3.4 Corporate Transactions. We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
3.5 Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
3.6 Consent. We may share or disclose your information with your consent.
3.7 Other business purposes. We may share or disclose your Personal Information for other business purposes as permitted by law or required to comply with legal obligations.
If we decide to modify the purposes for which your Personal Information is collected, used, or shared, or our practices relating to your Personal Information, we will amend this Privacy Policy as described below.
4. Cookies
When you access the CryptoTools Platform, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit the CryptoTools Platform. We use Cookies to help us recognize you as a customer, collect information about your use of the Platform to better customize our services and content for you, and collect information about your computer or other access devices to: (i) ensure compliance with our Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) program (“BSA/AML Program”) (ii) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities; (iii) assess and improve our services and advertising campaigns.
We may make use of third-party Cookies or analytics services, including but not limited to Google Analytics, Facebook, and MixPanel.
To learn more about Google Analytics and how to opt-out of making your activities available to Google Analytics, please visit https://marketingplatform.google.com/about/ or https://support.google.com/analytics/answer/181881?hl=en.
To learn more about how Facebook uses your data please visit https://www.facebook.com/help/325807937506242/ or log on to your Facebook account and access your settings. To understand more about Facebook advertising please see here https://www.facebook.com/about/ads.
To learn more about MixPanel, please visit https://mixpanel.com/legal/privacy-policy/.
Third-party tracking technologies are not controlled by us, and statements regarding our practices do not apply to these third-parties or their use of information. We make no representations regarding the policies or practices of such third parties. You may be able to opt out of the practices of some of these third parties if they are members of the Network Advertising Initiative (“NAI”) by visiting http://www.networkadvertising.org/choices or if they participate in the Digital Advertising Alliance (“DAA”) by visiting http://www.aboutads.info/choices. We are not responsible for the effectiveness of or compliance with any third-parties’ opt-out options.
We do not respond to browser “Do Not Track” signals.
You also can learn more about cookies by visiting https://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices.
Please note that if you reject cookies, you will not be able to use some or all of the CryptoTools Platform. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use the CryptoTools Platform.
5. Direct Marketing
Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from or about you. You may opt-out of such marketing communications at any time by visiting the Account Settings page on the CryptoTools Platform. You may also opt-out of such communications by following the directions provided in any marketing communication. It is our policy not to provide your Personal Information to third parties for their own direct marketing purposes without your consent. If you opt out of marketing communications, please note that we may still send you necessary information about transactions or our business relationship.
6. Children’s Personal Information
The CryptoTools Platform is not intended for children under the age of 18, and we do not knowingly collect Personal Information of children under the age of 18. If we learn that we have collected any Personal Information from a child under the age of 18, we will promptly delete it from our systems.
7. Information Security
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your Personal Information from loss, theft, or misuse, and from unauthorized access, disclosure, alteration, and destruction. Nevertheless, no security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect the CryptoTools Platform and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take may include encryption of the CryptoTools Platform website communications with SSL; required two-factor authentication for all sessions; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our employees, contractors, and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
8. Retention
We retain your Personal Information for as long as is reasonably necessary to provide services to you, for our legitimate business purposes, and to comply with our legal and regulatory obligations. If you close your account with us, we will continue to retain your Personal Information as necessary to comply with our legal and regulatory obligations, including for fraud monitoring, detection, and prevention; and for our tax, accounting, and financial reporting obligations.
9. International Transfers
CTS Services Group LTD. is a global business based in the Seychelles. As a result, Personal Information may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Information that we maintain about you to recipients in countries other than the country in which the Personal Information was originally collected. Those other countries may have data protection or privacy rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Information remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
If you are located in the European Economic Area (“EEA”), the UK or Switzerland, and are provided services by CTS Services Group LTD., we comply with applicable law to provide an adequate level of data protection for the transfer of your Personal Information to the Seychelles or other third countries. CTS Services Group LTD. enters into the appropriate data processing agreements and, if required, standard contractual clauses for the transfer of data which have been approved by the applicable data protection regulatory authority.
10. Information For California Residents
We are required under the California Consumer Privacy Act of 2018 (“CCPA”) to provide certain information to California residents about how we collect, use, and share their personal information, and about the rights and choices California residents may have concerning their personal information. For purposes of this section, “personal information” has the meaning provided in the CCPA.
Personal information that we collect, use, and share
For ease of reference, we have compiled the chart below to demonstrate how we use the categories of personal information we have collected, used, and disclosed in the past 12 months. We do not “sell” any personal information, as “selling” is defined under the CCPA.
California privacy rights
California consumers have the following additional rights under the CCPA with respect to their Personal Information. Please understand, however, that these rights are not absolute, and we may decline requests as permitted under applicable law.
Right to Request Access. You may submit a request that CTS Services Group LTD. disclose the categories of personal information we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of third parties with whom we share your personal information, and the specific pieces of personal information we have collected about you in the past 12 months.
Right to Request Deletion. You may submit a request that CTS Services Group LTD. delete the personal information about you that we have collected from you.
Right Not to Receive Discriminatory Treatment. You have the right to exercise the privacy rights conferred by the CCPA without discriminatory treatment.
You may submit a request to access or delete your personal information by following the “Exercise your privacy rights” link on your Account Profile page or by emailing us at privacy@CTSservicesgroup.com. We recommend that you submit your request through the Account Settings page because it is a more secure method than email. We are legally obligated to verify your identity when you submit a request. We may request additional information from you, like your date of birth or a personal identification number, to verify your identity. If we are unable to verify your identity, we may deny your request. If you submit a request to delete your personal information, you will also be required to confirm the deletion request by email.
You may designate an authorized agent to make a request under the CCPA on your behalf. Your authorized agent must submit proof that you have provided them with power of attorney pursuant to Probate Code sections 4000 to 4465. We may deny a request from a purported authorized agent who does not provide proof of authorization to act on your behalf.
Please understand that we are not obligated to provide you with access to your personal information more than twice in a 12-month period.
If your request is manifestly unfounded or excessive, we may either charge a reasonable fee or refuse to act on the request in which case we will notify you of the reason for refusing the request.
11. Information For Persons Subject To UK Data Protection Laws
If you are located in the EEA or the UK and are provided services by CTS Services Group LTD., we adhere to relevant UK data protection laws, and provide individuals with the following additional information. For purposes of this section, “personal data” has the meaning provided in the General Data Protection Regulation (EU) 2016/679 as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“GDPR”).
Lawful bases for processing
We process personal data subject to GDPR on one or more of the following legal bases:
Legal Obligation: to conduct anti-fraud and identity verification and authentication checks and to fulfill our retention obligations;
Contractual Obligation: to satisfy our obligations to you under our User Agreement, including to provide you with our services and customer support services, and to optimize and enhance CryptoTools;
Legitimate Interest: to monitor the usage of CryptoTools, conduct automated and manual security checks of our service, to protect our rights; and
Consent: to market CryptoTools and our services to you. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before consent is withdrawn.
European privacy rights
European Residents have the following rights under GDPR, subject to certain exceptions provided under the law, with respect to their personal data:
Rights to Access and Rectification. You may submit a request that CTS Services Group LTD. disclose the personal data that we process about you and correct any inaccurate personal data.
Right to Erasure. You may submit a request that CTS Services Group LTD. delete the personal data that we have about you.
Right to Restriction of Processing and Right to Object. You have the right to restrict or object to our processing of your personal data under certain circumstances.
Right to Data Portability. You have the right to receive the personal data you have provided to us in an electronic format and to transmit that Personal Information to another data controller.
When handling requests to exercise European privacy rights, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee for compliance with your request.
Automated decision-making
We may engage in automated decision-making for purposes of fraud detection and prevention. When we do, we implement suitable measures to safeguard your rights and freedoms and legitimate interests, including the right to obtain human intervention, to express your point of view, and to contest the decision.
12. Updates To this Privacy Policy
We may change this Privacy Policy from time to time to reflect changes to our privacy practices, enhance user experience, or comply with relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy. Your continued use of CryptoTools after our posting of changes to this Privacy Policy means that you understand and agree to such changes.