The main purpose of this document is to provide you with information about the processing of personal data carried out by Libertify (“Liberty” or “we”) in a concise, transparent, intelligible and easily accessible form, to help you understand how your data are processed.
In order to ensure fair and transparent data collection, we provide information on each processing operation we carry out by means of information notices.
Data are collected fairly. No data is collected without the knowledge or information of the data subjects.
When we process data, we do so for specific purposes: each data processing carried out by us has a legitimate, specified and explicit purpose.
For each of the processing carried out, we undertake to collect and use only data that are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
We ensure that the data are kept up to date and take steps to ensure that data that are inaccurate are erased or rectified.
In the context of the processing of personal data, the purposes of which are presented to you below, we collect and process the following categories of data:
Identification data of data subjects;
Data on the use of the services offered on the Libertify platform;
Data necessary for the management of the contract;
Your exchanges with Libertify;
You will be informed whether the data to be provided are mandatory or optional at the time of their collection. If you refuse to provide mandatory data, Libertify will not be able to provide you with the Services (such as the creation of your user account, access to the platform’s functionalities or the processing of your order).
If you provide us with the personal data of a third party, we remind you that you are required to inform that person of the disclosure and processing of their personal data by Libertify and to communicate this policy to them.
Users of the www.cryptoseatbelt.com site and the Libertify platform may be associated, by the devices, applications, tools and protocols they use, with online identifiers such as IP addresses, cookies or other connection identifiers. These identifiers may leave traces which, especially when combined with unique identifiers and other information received by the servers, may be used to create profiles of individuals and identify them. For more information on the cookies used by Libertify, please read our Cookie Policy.
The processing operations carried out by Libertify have the following purposes and legal bases:
| Purpose | Legal Bases |
| Ensuring the operation of the platform and the provision of servicesto users, in particular the establishment of a risk profile | Performance of the contract |
| Improving the quality and operation of the services | Legitimate interests |
| Managing contracts (managing and tracking orders, payments) | Performance of the contract |
| Keeping general accounting | Compliance with a legal obligation relating to a data storage requirement |
| Establishing financial statistics concerning customers | Legitimate interests |
| Monitoring customer relationship for complaint management | Performance if the contract |
| Managing prospects (notification of the launch of the platform)(2) | Consent |
| Managing requests from competent authorities or courts (communication of requested data) | Compliance with a legal obligation |
| Managing pre-litigation or litigation relating to the contract or not | Libertify’s legitimate interest in establishing proof of a right or contract(3) |
2. Note: we have noticed on the current version of the “https://cryptoseatbelt.com/” website the possibility for a user to enter their email address in order to be alerted of the launch of the platform. We therefore propose to keep this purpose, in the event that the privacy policy is posted online before the launch of the platform. Furthermore, as registering to this alert constitutes a form to collect personal data (the email address), we recommend adding the following essential information, in accordance with the CNIL’s recommendations: the identity of the controller, the purposes of the processing, the list of and method for exercising the rights of data subjects, and a reference to the privacy policy.
3. In this case, Libertify must carry out a balancing test which aims to ensure that Libertify’s legitimate interest would not infringe the fundamental rights and freedoms of the data subjects. In its Opinion No. 06/2014, the WP29 proposes to balance the interests of the controller against the fundamental rights and freedoms of the data subjects. In doing so, several elements should be taken into account, such as:
This balancing test must be documented so that it can, if necessary, be reproduced in response to any request that the CNIL may make.
@ 2023 Libertify SAS. All rights reserved.
@ 2023 Libertify SAS. All rights reserved.
Investing in digital assets is highly speculative and volatile, and cryptocurrency is only suitable for investors who are willing to bear the risk of loss and experience sharp drawdowns. Please note, all past performance or hypothetical/backtested performance as expressed on this site, is not indicative or a promise of future performance.
Investments in digital assets and cryptocurrency are Not FDIC Insured, Not SIPC Insured, Not Bank or Government Guaranteed, and May Lose Value. Before investing consider your investment objective, risk tolerance, Libertify’s fees and expenses and any trading related fees before investing. Although the goal of Libertify and the crypto seatbelt is to reduce volatility in your portfolio, there is no guarantee that your portfolio or account will not lose value, including risk of loss of your entire principal invested. Your account may experience significant drawdowns and there is no guarantee that Libertify will outperform a buy and hold strategy.
