Thank you for visiting protobank.ru (“ProtoBank” or the “Site”). Your use of the Site is being provided by one of the following parties (collectively, as “"we", "our", or "us"):
- ProtoBank Ltd. which is a U.S. corporation, if the user is a resident in a U.S. State and permitted to deposit or withdraw fiat and digital assets to commence digital asset trading;
- ProtoBank Inc. which is a U.S. corporation, if the user is a resident in a U.S. State and permitted to deposit or withdraw only digital assets to commence digital asset trading;
- ProtoBank LTD which is a Malta corporation, if the user is a resident of a country in the European Union, or
- ProtoBank Ltd Technology Company Limited which is a Hong Kong corporation, if the user is a resident of none of the above countries.
- ProtoBank Ltd Cyprus Limited a wholly owned subsidiary of ProtoBank Ltd Technology Limited with registered address at Souliou, 11, Vamiko 5, 1st Floor, Flat/Office 14, Strovolos, 2018, Nicosia, Cyprus and operational address at Athalassas 51, Strovolos 2012, Nicosia, Cyprus, acts as an agent of ProtoBank Ltd for selected services available to clients of ProtoBank Ltd.
“Digital Asset” means a digital asset (also called a “virtual financial asset”, “convertible virtual currency,” “cryptocurrency,” “virtual currency,” “digital currency,” or “digital commodity”), such as bitcoin or ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.
“Personal Data” means any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, such as your name, email address, username, contact details, identification number, location data, an online identifier such as IP address, device ID or one or more factors specific to the physical, economic, cultural or social identity of you.
- WHAT PERSONAL DATA WE COLLECT
ProtoBank Ltd collects, processes, and stores Personal Data via your use of the Service or where you have given your consent. This Personal Data may include contact details, copies of identification documentation provided by you or derived from publicly accessible databases, your government identification number as well as information relating to your device or internet service (such as an IP address and a MAC number).
In addition, we conduct business and collect Personal Data from individuals and entities located within the European Economic Area (“EEA”). We are required to protect Personal Data processed in the EEA in accordance with the General Data Protection Regulation (“GDPR”). To understand more about how we protect the data collected from individuals and entities located within the EEA, please see the details below.
We collect information you provide during the ProtoBank Ltd on-boarding process, which may be a completed, incomplete, or abandoned process. We also collect Personal Data when you communicate to us through customer support, subscribe to marketing communications, or correspond with us by phone, email or other communication channels. We collect, use, store, and transfer your Personal Data, which may include, without limitation, the following:
- Email address
- Mobile phone number
- Full legal name (including former name, and names in local language)
- Social Security Number (“SSN”), Passport number, or any government issued ID number
- Date of birth (“DOB”)
- Proof of identity (e.g. passport, driver’s license, or government-issued ID)
- Residential address
- Proof of residency
- Additional Personal Data or documentation at the discretion of our Compliance Team
- Corporate legal name (including the legal name in local language)
- Incorporation/registration Information
- Full legal name of all beneficial owners, directors, and legal representatives
- Address (principal place of business and/or other physical locations）
- Proof of legal existence
- Description of the business
- Percentage of ownership for Individual/corporate owners
- Contact information of owners, principals, and executive management (as applicable)
- Proof of identity (e.g., passport, driver’s license, or government-issued ID) for each individual beneficial owner that owns 10% or more of the institutional customer entity
- Personal Data for each entity’s beneficial owner that owns 10% or more of the institutional customer entity (see the “Individual Customer” section above for details on what Personal Data we collect for individuals)
- Source of wealth
- Amount of fiat to be injected
- Amount of bitcoin projected to be injected
- COLLECTION AND TRANSFER OF DATA OUTSIDE OF THE EEA
As outlined above, we collect Personal Data from customers located in the EEA. To facilitate the services, we provide to customers located in the EEA, we request explicit consent for the transfer of Personal Data from the EEA to outside of the area. If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to use ProtoBank Ltd and our services. You will have the ability to withdraw your digital assets and fiat currency; however, all other functionalities will be disabled.
- HOW WE USE YOUR PERSONAL DATA
ProtoBank Ltd uses Personal Data to administer, deliver, improve, and personalize the Service for you and to comply with our legal and regulatory obligations. We may also use such data to communicate with you in relation to other products or services offered by ProtoBank Ltd and/or its partners.
You agree that ProtoBank Ltd has the right to share your Personal Data with:
- Member of our group, which includes our subsidiaries, holding companies and companies under common control including their respective contractors, affiliates, employees or representatives;
- Our service providers and other third parties who assist us in providing Service to you;
- Entities in connection with any financing, acquisition or dissolution proceedings which involve disclosing certain portion or all of our business or assets; and
- Law enforcement agencies and authorities, officers, regulators or other third parties to comply with any law, court order, subpoenas or government requests;
Additionally, we have implemented international standards to prevent money laundering, terrorist financing and circumventing trade and economic sanctions, which requires us to undertake due diligence on our customers. This may include the use of third-party data and service providers which we will cross-reference with your personal information.
- HOW WE STORE YOUR PERSONAL DATA
The data that we collect from you may be transferred to, stored at, a destination outside of the country of your residence. It may also be processed by staff operating outside of your residence who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing, except customers located in the EEA, as detailed above.
- ACCESS CORRECTION, AND DELETION OF YOUR PERSONAL DATA
You have the right to obtain a copy of your Personal Data upon request and ascertain whether the information we hold about you is accurate and up-to-date. If any of your Personal Data is inaccurate, you may request to update your information. You may also request to delete your Personal Data, with exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. For data access, correction, or deletion requests, please contact email@example.com with the subject “DATA INQUIRY”.
In response to data access, correction, or deletion request, we will verify the requesting party’s identity to ensure that he or she is legally entitled to make such request. While we aim to respond to these requests free of charge, we reserve the right to charge you a reasonable fee should your request be repetitive or onerous.
Customers can opt out from these marketing communications at any moment. If you do not want to receive these communications, please send an email to firstname.lastname@example.org.
For product related communications, such as policy/terms updates and operational notifications, you will not be able to opt out of receiving such information.
- COOKIE USAGE
While you access ProtoBank Ltd, we may use the industry practice of placing a small amount of data that will be saved by your browser (Cookies). This information can be placed on your computer or other devices used to visit ProtoBank Ltd. This information helps us recognize you as a customer, collect information about your use of ProtoBank Ltd to better customize our services and better your experience. We may also use the information collected to ensure compliance with our Bank Secrecy Act (“BSA”) and Anti-Money Laundering (“AML”) program (“BSA/AML Program”), and to ensure your account security has not been compromised by detecting irregular or suspicious account activities.
Most browsers are setup to accept cookies automatically. Some Cookies expire when you finalize the session and other Cookies remain on your computer or other devices until deleted or expired. You have the option to decline the use of our Cookies, but this may affect the functionality of ProtoBank Ltd services or your user experience.
- INFORMATION SECURITY
We endeavor to protect ProtoBank Ltd and you from unauthorized access, alteration, disclosure, or destruction of Personal Data we collect and store. We take various measures to ensure information security, including encryption of the ProtoBank Ltd communications with SSL; required two-factor authentication for all sessions; periodic review of our Personal Data collection, storage, and processing practices; and restricted access to your Personal Data on a need-to-know basis for our employees and vendors who are subject to strict contractual confidentiality obligations.
- CONTACTING ProtoBank Ltd ABOUT PRIVACY QUESTIONS OR CONCERNS
For customers from EEA, you have right to make compliant for unresolved questions in relation to the collection, use or disclosure of your Personal Data to the applicable supervisory authority within your jurisdiction.