1. 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.
2. In order to ensure fair and transparent data collection, we provide information on each processing operation we carry out by means of information notices.
3. Data are collected fairly. No data is collected without the knowledge or information of the data subjects.
4. When we process data, we do so for specific purposes: each data processing carried out by us has a legitimate, specified and explicit purpose.
5. 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.
6. We ensure that the data are kept up to date and take steps to ensure that data that are inaccurate are erased or rectified.
7. 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:
8. 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).
9. 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.
10. 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.
11. The processing operations carried out by Libertify have the following purposes and legal bases:
|
No. |
Purposes |
Legal bases |
|
1. |
Ensuring the operation of the platform and the provision of services to users, in particular the establishment of a risk profile |
Performance of the contract |
|
2. |
Improving the quality and operation of the services |
Legitimate interests |
| 3. | Managing contracts (managing and tracking orders, payments) |
Performance of the contract |
|
4. |
Keeping general accounting |
Compliance with a legal obligation relating to a data storage requirement |
|
5. |
Establishing financial statistics concerning customers |
Legitimate interests |
|
6. |
Monitoring customer relationship for complaint management |
Performance of the contract |
|
7. |
Managing prospects (notification of the launch of the platform)(2) |
Consent |
|
8. |
Managing requests from competent authorities or courts (communication of requested data) |
Compliance with a legal obligation |
|
9. |
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.
12. The recipients of your data are:
13. We ensure that only authorised persons of those recipients have access to these data. Libertify has a strict clearance policy which ensures that the data it processes are only shared with those authorised to access them.
14. The personal data collected by Libertify or its processors are processed exclusively in the European Union. This also means that the data are stored in the European Union, can only be accessed by natural or legal persons located, domiciled or established in the European Union and can only be transferred between European Union countries.
15. We ensure that data are kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data are processed.
16. The periods for which we keep your personal data are proportionate to the purposes for which your data were collected.
17. More precisely, our data storage policy is organised as follows:
|
No. |
Purposes |
Storage period |
|
1. |
Ensuring the operation of the platform and the provision of services to users, in particular the establishment of a risk profile |
The data are kept for the duration of the contractual relationship.Connection data are kept for 1 year. Beyond this period, only the data necessary for pre-litigation or litigation purposes are archived until the statutory limitation period has expired, it being specified that the ordinary law limitation period in civil and commercial matters is five (5) years. |
|
2. |
Improving the quality and operation of the services |
The data are kept for the time necessary to achieve the purpose of the study or until the right to object or to withdrawal consent is exercised. |
| 3. | Managing contracts (managing and tracking orders, payments) |
The data are kept for the duration of the contractual relationship. |
|
4. |
Keeping general accounting |
Accounting data and business documents (such as invoices, order forms, commercial correspondence) are subject to intermediate archiving for the legal storage period, i.e. up to ten (10) years from the end of the accounting period. |
|
5. |
Establishing financial statistics concerning customers |
The data are kept for the time necessary to achieve the purpose of the statistics or until the right to object is exercised. |
|
6. |
Monitoring customer relationship for complaint management |
The data are kept for the duration of the contractual relationship. |
|
7. |
Managing prospects (notification of the launch of the platform)(8) |
The data are kept for a period of 3 years from the date of collection or the last contact from the prospect (e.g. date of the request to be notified of the launch of the platform).(9) |
|
8. |
Managing requests from competent authorities or courts (communication of requested data) |
The data are kept only for the time necessary to process the request of the competent authority or court. |
|
9. |
Managing pre-litigation or litigation relating to the contract or not |
Where applicable, the data are kept for the duration of the pre-litigation or litigation. In the case of a pre-litigation, the data are then archived until the dispute is settled out of court or, failing that, as soon as the corresponding legal action is time-barred. In the case of litigation, the data are archived until the ordinary and extraordinary remedies are no longer available against the decision issued. |
8. 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.
9. Maximum period recommended by the CNIL (Deliberation n°2016-264 of 21 July 2016 amending a simplified standard – NS-048). NB: if the prospect is a customer, the recommended storage period is 3 years from the end of the contractual relationship. At the end of this period, the controller may contact the prospect to find out whether they wish to continue receiving marketing messages. In the absence of a positive and explicit response from the person, the data will have to be permanently deleted.
18. The security of your personal data is very important to Libertify.
19. We have implemented technical and organisational measures appropriate to the degree of sensitivity of the personal data, in order to ensure the integrity and confidentiality of the data and protect them against malicious intrusion, loss, alteration or disclosure to unauthorised third parties.
20. Libertify chooses its subcontractors and service providers with care and requires that:
21. Where we use a service provider, we will only disclose personal data to them after obtaining a commitment and guarantees from them that they will be able to meet security and confidentiality requirements.
22. In compliance with our legal and regulatory obligations, the contracts concluded with our processors set out precisely the terms and conditions of the processing of personal data by them in accordance with personal data protection laws.
23. When using the Libertify site, application and platform, cookies or other trackers may be installed on the administrator’s or user’s terminal.
24. All the information concerning the cookies that may be set during such use is detailed in Libertify’s Cookie Policy, which is accessible on its website at the following address: (to be completed) and from the footer of each of the pages of Libertify’s site or platform.
25. Libertify is committed to respecting your rights in relation to the data we process, in order to guarantee fair and transparent processing taking into account the particular circumstances and context in which your personal data are processed.
26. You must use the services of the site and all the information to which you may have access exclusively for personal purposes and in a manner that is consistent with public policy, morality and third party rights.
27. You must not interfere with the use that other users may make of the Libertify site, application or platform, not access the accounts of third party users, and not access restricted areas of the Libertify site, application or platform that you are not authorised to access.
28. You have the right to obtain confirmation as to whether or not your personal data are being processed and, where that is the case, access to your data and the following information:
29. In connection with the right of access, Libertify may charge you a reasonable fee based on administrative costs for any copy of the personal data undergoing processing beyond that.
30. You have the right to ask us, as the case may be, to rectify or complete your personal data that are inaccurate, incomplete, ambiguous or expired.
31. You have the right to ask us to erase your personal data in the cases provided for by laws and regulations, including where one of the following grounds applies:
32. Please note, however, that the right to erasure is not a general right and can only be exercised if one of the reasons provided for in the applicable laws is met.
33. Therefore, if none of these reasons is met, Libertify will not be able to act upon your request; this will be the case if Libertify is required to retain the data for compliance with a legal or regulatory obligation or for the establishment, exercise or defence of legal claims.
34. The right to restriction complements the other rights you have. This right means that our processing of your data is restricted, so that we can keep the data, but we cannot use or process them in any other way.
35. This right applies in specific cases:
36. You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on the legitimate interest pursued by the controller (see clause above on the legal bases for processing).
37. If you exercise your right to object, we will no longer process your personal data for the processing concerned unless we demonstrate compelling legitimate grounds for the processing which must override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
38. You have the right to portability of your personal data. Please note, however, that the right to data portability is not a general right. Not all data from all processing operations are portable; the right to data portability only concerns processing carried out by automated means to the exclusion of manual or paper processing.
39. This right is limited to processing based on your consent, on the performance of a contract or on the taking of steps prior to entering into a contract.
40. This right does not include derived or inferred data, which are personal data created by Libertify.
41. You have the right to lodge a complaint with the CNIL (3 place de Fontenoy 75007 Paris) on the French territory without prejudice to any other administrative or judicial remedy.
42. You have the right to give special instructions on how your personal data should be stored, erased and shared after your death. These special instructions only concern, and will be limited to, the processing carried out by us.
43. You also have the right, when that person will be designated by the executive branch, to give general instructions for the same purpose.
44. You may exercise the rights listed above by sending a request, together with a document proving your identity by any means, by email to info@cryptoseatbelt.com or by post to 118 rue de Lauriston, Paris 75016.
45. This Privacy Policy has been drafted in French and in (to be completed).
46. In the event of a dispute between the parties, only the French language version shall be considered legally valid.
47. We invite you to consult this policy on our website regularly. It may be updated at any time.
48. Last updated: 5th Jan 2023
@ 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.
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, Crypto Seatbelt’s fees and expenses and any trading related fees before investing. Although the goal of 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 Crypto Seatbelt will outperform a buy and hold strategy.
