Privacy Policy

This Privacy Policy explains how Coinme Inc. d/b/a Coinme, and our subsidiaries and affiliated companies (“Coinme,” “we,” “our,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our kiosks, websites, mobile applications, and other online products and services, contact our customer service team, interact with us on social networking sites where we have an official presence, or otherwise interact with us (collectively, our “Services”).  This Policy will not apply where we display or link to a different privacy policy.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with more prominent notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to review this Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

Collection of Information

Use of Information

Sharing of Information

Advertising and Analytics

Transfer of Information to the United States and Other Countries

Your Choices

Special Notice to California Residents

Special Notice to Illinois Residents

Special Notice to Vermont Residents

Contact Us

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, you share information directly with us when you visit a kiosk, create an account, fill out a form, submit or post content through our Services, make a purchase, initiate a transaction, communicate with us via third-party platforms, request customer support, sign up for contests, sweepstakes, promotions, mailing lists or events, or otherwise communicate with us. The types of the information we may collect from you include:

• Identity Information, such as your first name, maiden name (where applicable), last name, postal and email address, telephone number, username or similar identifier, marital status, nationality, date of birth, gender, photograph, government-issued identity card or number, driver’s license, passport number, biometric information, full-facial photograph, and demographic information.
• Financial Information, such as your bank account, payment details, Services portfolio details, cryptocurrency wallet, and/or information regarding certain virtual financial assets.

• Transactional Information, such as:
  • type of virtual financial assets involved, order volume, price, value, and, where applicable, derived proceeds;
  • your trading and transactional history using the Services, including withdrawals and order activity; and
  • charges to or payments by you for your use of the Services.
• Anti-Money Laundering (“AML”) / Know Your Customer (“KYC”) Information, such as the following:  (i) a copy of government-issued identification document such as a driver’s license, identification card, or passport, (ii) proof of residency such as a utility bill, (iii) KYC database checks, (iv) fraud database checks, and (v) any documentation or information which we may, from time to time be required to collect by any competent national or foreign authority or law enforcement agency to confirm compliance with applicable laws or regulations and/or AML/KYC practices.

Information We Collect Automatically When You Interact with Us

When you access or use our Services or otherwise transact business with us, we automatically collect certain information, including:

• Activity Information: We collect information about your activity on our Services, such as the date and time you visit a kiosk.
• Transactional Information:  When you use our Services, we collect information about your transaction, including but not limited to the transaction amount, exchange rate, destination wallet address for any virtual currency sent, voucher redemption information, and transaction date, time, and location.
• Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, language preference, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the sites you visited before navigating to our Services.
• Location Information: In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).
• Information Collected by Cookies and Similar Tracking Technologies: We and our service providers use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, understand usage and campaign effectiveness, and determine if an email has been opened and/or acted upon. For more information about cookies and how to disable them, see the Your Choices section below.

Information We Collect from Other Sources

We obtain information from third-party sources. For example, we may collect information about you from identity verification services, credit bureaus, advertising networks, data analytics providers, and mailing list providers. Additionally, if you create or log into your Coinme account through a third-party platform (such as Facebook or Google), we will have access to certain information from that platform, such as your name, birthday, and profile picture, in accordance with the authorization procedures determined by such platform.  Another source of personal information is the person from whom you receive money.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.

USE OF INFORMATION

We use the information we collect to provide, maintain, and improve our Services. We also use the information we collect to:

• Conduct KYC and AML diligence, including establishing and verifying your identity and source of funds/wealth, following your request to open and register an account for you;
• Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and related notices;
• Personalize and improve your experience with our Services;
• Send you technical notices, security alerts, and support and administrative messages;
• Respond to your comments and questions and provide customer service;
• Communicate with you about products, services, and events offered by Coinme and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
• Provide and administer surveys and our loyalty program, sweepstakes, or similar programs;
• Monitor and analyze trends, usage, and activities in connection with our Services;
• Deliver relevant website content, personalize, and measure or understand the effectiveness of the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);
• Deliver relevant website content, personalize, and measure or understand the effectiveness of the advertisements you see when you use our Services based on information provided by our advertising partners;
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
• Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Coinme and others;
• Debug to identify and repair errors in our Services;
• Comply with our legal, financial, and reporting obligations; and
• Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

To provide, maintain, and improve our Services, we may share personal information with:

• With vendors, service providers, and consultants to perform services for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, and marketing and advertising.
• Integration partners if you choose to use integrations we offer on our Services, such as sharing your location through our Google Maps integration.
• Third parties for their own services and marketing purposes, unless you opt out of this type of sharing by emailing us at [email protected].
• External parties:  (1) if we believe your actions are inconsistent with our user agreements or policies, you have violated the law, or it is necessary to protect the rights, property, and safety of Coinme, our users, the public, or others; or (2) in connection with, or during negotiations concerning, any merger, sale of Coinme assets, financing, or acquisition of all or a portion of our business by another Coinme.
• Our current and future parents, affiliates, agents, associates, subsidiaries and other companies under common control and ownership to support your use of the Services and facilitate your relationship with us.
• Regulators, law enforcement agencies, and other authorities as required by applicable law and circumstances.
• Other organizations for fraud protection or credit risk reduction purposes.
• Your consent or at your direction.

We also share aggregated or de-identified information that cannot reasonably be used to identify you.

ADVERTISING AND ANALYTICS

We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Coinme and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices (in the United States) or http://www.youronlinechoices.eu (in Europe). Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

California Do Not Track Disclosures

California law requires us to let you know how we respond to web browser “Do Not Track” signals.  Because there currently is not an industry or legal standard for recognizing or honoring such signals, we do not respond to them at this time.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Coinme is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

YOUR CHOICES

Account Information

You may update and correct certain account information at any time by logging into your account or emailing us at [email protected]. If you wish to deactivate your account, please email us at [email protected]; however, please note we may retain certain information as required by law or for our legitimate business purposes.

Location Information

When you first launch any of our Services that collect precise location information, you will be asked to consent to the collection of such information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. You may also stop our collection of this location information by following the standard uninstall process to remove all of our mobile apps from your device. If you stop our collection of this location information, our Services may no longer function properly.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications Preferences

You may opt out of receiving text messages or promotional emails from Coinme by following the instructions in those communications or by emailing us at [email protected].  If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

SPECIAL NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

California Consumer Privacy Act

In the preceding 12 months, we have collected the following categories of personal information:  identifiers, personal information categories listed in the California Customer Records statute (Cal. Civ. Code Sec. 1798.80(e), protected classification characteristics under California or federal law, commercial information, internet or other similar network activity, geolocation data, professional or employment-related information, and inferences.  For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

We do not sell your personal information to third parties in exchange for money.

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. You may make these requests by emailing us at [email protected].  We will verify your request by asking you to provide information related to your account such as your government-issued identification number or date of birth.  We will not discriminate against you if you exercise your rights under the CCPA.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please Contact Us.

We offer various financial incentives.  For example, we may provide sweepstakes, promotions, and other benefits for customers who sign up to receive our marketing emails or join certain programs. When you participate in a financial incentive, we collect personal information about you such as your name, email address, and commercial information like your purchase history. You may opt into a financial incentive by following the sign-up instructions and may later opt-out of the incentive at any time by emailing us at [email protected].  In some cases, when you sign up for a financial incentive, we may provide additional information, terms, and conditions related to such incentive. The value of your personal information is the value of the offer or discount presented to you.

SPECIAL NOTICE TO ILLINOIS RESIDENTS

The Illinois Biometric Information Privacy Act or BIPA (740 ILCS/14) affords Illinois residents certain rights relating to their personal information.  If you are an Illinois resident, this section applies to you.  Coinme may collect, capture, purchase, receive through trade, or otherwise obtain biometric information (such as photographs used to conduct facial geometry scans) in support of our AML/KYC diligence efforts and other purposes described in the Use of Information section above and pursuant to the Coinme Terms of Service.

SPECIAL NOTICE TO VERMONT RESIDENTS

Pursuant to Vermont Regulation B-2018-01, Coinme does not share information it collects about Vermont residents outside of our subsidiaries and affiliated companies unless legally permitted. For example, with your consent, we may share Vermont resident information to maintain your account or pursuant to joint marketing agreements with financial institutions with which we have executed agreements. Additionally, with your consent, we may share information about your creditworthiness with our subsidiaries and affiliated companies; however, we may share information about your transactions or our experiences with you with our subsidiaries and affiliated companies without your consent.  For additional information about Coinme’s information disclosure practices, please see the Sharing of Information section above or contact us.

CONTACT US

If you have any questions about this Privacy Policy, please email us at [email protected]