We understand that privacy is an important issue to you, and we respect the privacy of our consumers, clients, and users. We aim to protect the security and confidentiality of Personal Information about you that we acquire.
Under the law you have the right to limit some, but not all, sharing of your Personal Information. The law also requires us to disclose to you how we collect, share and protect your Personal Information.
Please see our Privacy Notice for additional information about how we use and share information we obtain to provide financial services and products.
Personal Information We Collect:
Other Information We Collect
We also collect other information in the form of aggregated statistics that does not uniquely identify you as an individual. This information is referred to as “deidentified information”. We collect deidentified information when you interact with us and use our services and products. Examples may include traffic visits on the website and web application, information on the links you click, the features of our website that you use, and the types of information you upload. We may share deidentified information with our advertising and marketing agents to evaluate the effectiveness of our marketing programs. Additionally, we may use this information to analyze your usage of our website and for other research that help us improve the services and products we offer.
How We Collect Your Personal Information
We collect your Personal Information from the following sources:
Direct Interactions. You provide your Personal Information when you use our services and products, open an account with us, request marketing information, enter a sweepstakes, or contact us with questions or requests.
Technological Interactions. When you use our services and products, we automatically collect Personal Information through cookies (see Cookies).
Third Parties. We collect Personal Information from third parties as required or permitted by applicable law. Third-party sources may include public databases, credit bureaus, identity verification partners, resellers and channel partners, joint marketing partners, and social media platforms.
Why We Collect and Use Your Personal Information
We only collect and use your Personal Information, as required or permitted by applicable law, for the following purposes:
In connection with our provision of services and products to you in order to meet our contractual obligations to you;
Where it is necessary for our legitimate interests. For example, conducting background checks for Know Your Customer (KYC) reviews and Anti-Money Laundering (AML) Watchlists, sending you notices regarding your money/cryptocurrency transfers to and from Virtual Global Cooperative , sending you confirmations and other information on your cryptocurrency transactions, to create your account statements, maintaining records on your transactions and providing support to your account generally;;
To deliver content about our services and products, and to send promotional and other information to you; and;
To conduct analysis regarding your usage of our services and products and the effectiveness of our marketing initiatives.;
We will not use your Personal Information for purposes other than those purposes we have disclosed to you without your permission. If we need to use your Personal Information for an unrelated, new, or additional purpose, we will notify you and obtain your consent to use it for such unrelated, new, or additional purpose.;
Legal Basis for Collecting and Using Your Personal Information
We rely on the following legal bases, as required by applicable law, to collect and use your Personal Information:
Where collection and use of your Personal Information is necessary for the performance of a contract (e.g., using your information to deliver a purchased service or product);
Where the collection and use of your Personal Information is required to comply with the law;
Where the collection and use of your Personal Information is necessary for our legitimate interest provided it does not override your rights and freedoms; and
Where you have given us your consent to collect and use your Personal Information.
Sharing Your Personal Information
We do not disclose your Personal Information to any third parties, except to those who require access to the data in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. This may include but is not limited to, any obligations of Virtual Global Cooperative under the Switzerland PATRIOT Act, and in order to facilitate the execution of our clients’ cryptocurrency transactions in the ordinary course of business.
We share the categories of Personal Information as outlined in “Personal Information We Collect” with the following categories of third parties:
We are required to validate our clients’ identities by applicable laws and regulatory requirements and rely on third-party services to perform these validations. Personal Information that you provide to us during the account opening process is passed to these services at account opening and on an ongoing basis thereafter.
We share your information with financial institutions with which we partner to process payments which you have authorized.
We may share analyses based on anonymous client information or behavior with our affiliate companies in order to operate and improve products and services.
We may disclose or transfer information we collect to a purchaser of our business.
We may disclose or transfer information we collect upon account closing where you have a deficient balance, or upon excessive instances where you do not have sufficient funds in your account.
We may disclose Personal Information to third parties that provide services, such as, but not limited to, consulting, sales, client support operations, payment processing, authentication services, and technical support or services.
We may share your information with law enforcement, and officials, or other third-parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of our terms and conditions or any other applicable policies.
We may disclose information to third parties about your account or the transactions you make if you give us your written permission.
Other circumstances under which we may disclose your Personal Information include to:
Comply, as necessary, with applicable laws and regulatory requirements, as well as legal process;
Respond to mandatory legal or governmental requests or demands for information;
Meet national security requirements;
Protect ourselves, our affiliates, our clients, our counterparties or the general public from illegal activities; and
Respond to an emergency that requires disclosure of specified.
Opting Out of Sharing Your Personal Information
From time to time we may request your permission to allow us to share your Personal Information with third parties. You may opt out of having your Personal Information shared with third parties, or from allowing us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your Personal Information, certain features or BlockFi services may not be available to you.
We may have links to unaffiliated third-party websites on our website. These third-party websites have their own privacy policies. We have no involvement with their policies and are not responsible for their practices. You are encouraged to review the privacy policies of all third-party websites you visit.
We, or our service providers on our behalf, may use your Personal Information to send you marketing and promotional communication that we believe may enhance your experience with our services or products, or may be of interest you. If you do not want to receive marketing and promotional communication from us, you can opt-out at any time by contacting us, or by unsubscribing via the links provided in the marketing emails.
Sale of Your Personal Information
Currently, we do not sell your Personal Information.
Personal Information of Minors
Our services and products are not intended for individuals under the age of eighteen (18). We do not knowingly collect and use Personal Information related to minors.
Cookies are small text files sent from a site to the hard drive of a user's device to store bits of information related to that user or device. First-party cookies are put on your device directly by our website, which allows us to collect analytical data and provide other useful functions that create a good user experience. Third-party cookies are placed on your device by a third party (e.g., advertiser or analytic system). The third parties who serve cookies on our site may link your name or email address to other information they collect, which may include past purchases made offline or online, or your online usage information.
We use the following types of cookies:
Functional Cookies allow our website to provide enhanced functionality. For example, we use these cookies to notify you of account updates, notifications, and reminders. You may refuse to accept these cookies; however, this may affect access to certain parts of our website. Additionally, you may not be able to take advantage of personalized features.
Performance Cookies collect information about how you use our website, for example, which pages you visited and which links you clicked on. The information collected is aggregated and cannot be used to identify you.
Marketing Cookies may be set on our website by our advertising and marketing service providers. They are used to track your online activities and help us provide relevant advertising, links, or other information about our services and products to users visiting other websites after visiting our website.
Virtual Global Co-operative strives to ensure that our systems are secure and that they meet industry standards. We seek to protect non-public Personal Information that is provided to the site by third parties and you by implementing physical and electronic safeguards. Where we believe appropriate, we employ firewalls, intrusion prevention, encryption technology, user authentication systems (i.e. passwords and personal identification numbers) and access control mechanisms to control access to systems and data. Virtual co-operative endeavors to engage third-party service providers that have security and confidentiality policies, if such third-party service providers have access to our client’s Personal Information. We instruct our employees to use strict standards of care in handling the personal financial information of clients. As a general policy our staff will not discuss or disclose information regarding an account except with authorized personnel of our service providers or as required by applicable law and regulatory requirements law or pursuant to regulatory request and/or authority.
Despite our efforts to protect the security of your information, no security system is always effective, and we cannot guarantee that our systems will be completely secure.
We are required under applicable laws and regulatory requirements to retain certain information, including Personal Information of clients. Such records are generally retained as required by law, rule or regulation or for the minimum amount of time necessary to accomplish the purpose for which it was collected, and thereafter no longer than is permitted under Virtual Global Co-operative data retention policies.
However, even after you deactivate your account, we can retain copies of information about you and any transactions or services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our services and products, to assist with investigations, to enforce any of our terms and conditions or other applicable agreements or policies, or to take any other actions consistent with applicable law.
Your Privacy Rights
Depending on the jurisdiction where you reside, you have certain rights over the Personal Information we collect about you. You may exercise the rights, based on the applicable jurisdiction, at any time by logging into your account and clicking the Profile or My Account tab or by contacting us. Note that we may refuse to grant your requests in whole or in part as permitted by applicable law.
Information We May Need from You
We may need to request specific information from you (e.g. name and email address) to help us confirm your identity and verify your request. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it, and that your Personal Information is not deleted at the request of anyone but you. We may also contact you to ask you for further information in relation to your request.
Time to Respond to Your Requests
We try to respond to all legitimate and verifiable requests within thirty (30) days. Occasionally, it may take us longer than thirty (30) days if your request is particularly complex, you have made several requests, or additional information is needed from you to process your request. In this case, we will notify you within the thirty (30)-day period and keep you updated.
If you have an account with us, we may deliver our response to that account. If you do not have an account with us, we will deliver our response by mail or electronically. If we cannot comply with your request, we will provide a detailed explanation of why we cannot comply.
You will usually not have to pay a fee to exercise any rights listed above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may refuse to comply with your request under these circumstances.