Innprove Investments B.V. (Innprove or we/our) takes your privacy seriously and handles all your personal data with the utmost care. In this privacy statement, we explain which personal data are processed when you use the services of Innprove for automatic trading and investing in (virtual/crypto)currencies (the Services). Further, we will inform you for what purposes we process your data and what rights you have with regard to the processing of your personal data. We therefore advise you to read this privacy statement carefully.
1. About Innprove
The party responsible for the processing of your personal data is Innprove Investments B.V., having its statutory seat in Amsterdam and its address at Hengelosestraat 500, 7521 AN, Enschede, the Netherlands, registered with the Chamber of Commerce under 73803820. All questions regarding the processing of personal data by Innprove can be addressed to email@example.com.
2. To whom does this privacy statement apply?
This privacy statement applies to every person that makes use of Services offered by Innprove, contact forms, customer service and/or visits https://www.innprove.com or any subdomains or any website that replaces this website (the Website).
3. Which personal data are processed by Innprove, why and on what basis?
Below you will find – for each category – an overview of the purposes for which Innprove processes your personal data. Subsequently, we state which personal data are used for which specific purpose, what the legal basis is for the processing of data and for how long the personal data will be retained.
Create an account and use our Services
Personal data. After you have created an account at Innprove and provided all required information, you can use our Services. To create an account, we request that you submit personal data such as name, address, email address, telephone number and nationality.
Purpose. We process the abovementioned data to create an account for you allowing you to use our Services and to identify you as user of your account and our Services and to provide you with an invoice.
Basis. The information is necessary for the execution of the agreement with you.
Retention period. Innprove stores the data no longer than necessary. For the account, your personal data will be retained as long as the account has not been terminated. If the account and our agreement is terminated, Innprove will keep the data for a period of five (5) years or seven (7) years, taking into account a legal retention obligation of at least seven (7) years which applies to the processing of payment data, which is part of our administration
Personal data. When using our Services the account details, order details, and trade details (including fees), are retained. These account details are connected to your (exchange) account and personal details and are therefore considered personal data.
Purpose. We process this information to provide our Services and to provide you with an invoice for the Services.
Basis. This information is necessary for the execution of the agreement with you.
Retention period. The account information is stored as long as the account has not been terminated. If the account is terminated, Innprove will keep the data for a period of 5 years. Furthermore Innprove is obliged to store payment data, which is part of the debtor administration, for at least seven (7) years.
Personal data. If you submit your email address because you want to receive our newsletter, Innprove will process the email address you entered.
Purpose. The collected email address is used to inform you of relevant offers and/or news from Innprove.
Basis. The processing of your email address is based on the legitimate interest that Innprove has, after you have registered for the newsletter, to inform you about offers and other news concerning Innprove.
Retention period. If you no longer wish to receive the newsletter, there is the possibility to unsubscribe. In case you unsubscribe, Innprove can store your information for a period of 6 months.
Personal data. If you contact the customer service of Innprove with questions or complaints about the Services, Innprove will collect your contact details and your question or complaint. Innprove can ask you to provide more information if it finds it necessary for answering the question or handling the complaint.
Purpose. The information collected in this way is used for answering questions and handling complaints.
Basis. Innprove has a legitimate interest to process this information in order to effectively reply to your questions and complaints and to optimize its customer service.
Retention period.After the contact moment, we will not keep your data longer than 6 months.
Personal data. Innprove automatically collects information about your surfing behaviour during your use of the Website. This information consists of your IP address (the number of your computer that makes it possible to recognize your computer), the type of browser (the computer program to be able to view internet pages), the browser language, the computer system that you use, the pages you visit and the duration of a session. We obtain this information by placing cookies.
Purpose. This information is collected in order to improve your experience on the Website of Innprove and to solve technical problems and security issues and, in case of tracking cookies, for advertising purposes.
Basis. This processing of your data is necessary for the legitimate interests of Innprove to secure its Website and to offer it as user-friendly as possible. In the event we use tracking cookies, we process personal data collected by means of these tracking cookies based on your consent.
Retention period. The information will be stored in accordance with the legal retention periods.
4. When does Innprove provide personal information to third parties?
Innprove only provides information to third parties when this is lawful and is done carefully. Innprove can provide your information to third parties if this is necessary for the execution of the Services, if you have given permission for this or if this is mandatory under the General Data Protection Regulation (GDPR). In addition, Innprove may provide your personal data to third parties as a result of a lawsuit and/or on request of an authorised supervisory authority and/or if we believe that this is necessary to protect our rights.
5. Transferring personal data outside the European Economic Area (EEA)?
Your personal data is not stored by Innprove outside the EEA. Should Innprove decide to store your data outside the EEA at a later stage, it will do so with due observance of the legal conditions imposed by mandatory legislation.
6. How does Innprove protect your information?
Innprove is committed to ensure that your personal data is secured. In order to prevent unauthorized access or disclosure, Innprove takes appropriate technical and organizational measures to protect your personal data against loss or any form of unlawful processing. Exchange between personal data, between the Website and our users, happens over a SSL secured communication channel and is encrypted and protected with digital signatures.
7. What are your rights?
Under the GDPR you have a number of rights with regard to your data and the processing of it.
Right of access: you have the right to submit a request to find out whether Innprove processes personal data relating to you. If this is the case, Innprove will provide you with a copy of the personal data collected in accordance with the law.
Right to rectification: you have the right to submit a request for rectification of inaccurate personal data. If possible, you also have the right to provide additional personal data in order to complete the collection of your personal data.
Right to be forgotten: you have the right to request the deletion of (certain) personal data relating to you (the right to be forgotten). If your request is granted, Innprove will delete the relevant personal data.
Right to restriction of processing: you have the right to file a request to restrict the processing of your personal data. This means that, if the request is granted, Innprove will not process your personal data during the term of restriction.
Right to object: you have the right to, under certain circumstances, object to the processing of your personal data, for example if Innprove processes your personal data based on legitimate interest. If you object, Innprove will weigh your privacy interest against the business interest of Innprove. Should your interest override the interest of Innprove, Innprove will no longer process your personal data. If we use your personal data for direct marketing purposes, you can always object to this processing. In that case Innprove will no longer process your personal data for that purpose.
Right to data portability: you have the right to submit a request for data portability. If granted, Innprove will make your data available to you in a structured, commonly used and machine-readable format in order for you to transfer it to a third party.
Withdraw consent: where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Your requests can be sent to firstname.lastname@example.org. Innprove tries to respond to your request as soon as possible, but in any case within one (1) month after receipt. If Innprove needs more time, you will be informed. In no case Innprove will respond to you later than two (2) months. Innprove will inform you within one (1) month of receipt of the request if such an extension will take place, stating the reason for the delay.
In order to ensure that the information you request is actually yours, we may ask you to send a valid proof of identity. If Innprove cannot (fully) determine to which personal data your request relates, Innprove can ask you to (further) specify your request.
If Innprove does not take action on your request, for example because your request is unfounded or excessive or because Innprove (legally) cannot or does not have to comply with your request, Innprove shall inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action. In that case, you also have the right to lodge a complaint with the supervisory authority and to seek a judicial remedy. A complaint can be filed with the Dutch data protection authority via this link: https://autoriteitpersoonsgegevens.nl/nl/klachtenformulier.
8. Can this privacy statement be amended?
This privacy statement can be amended from time to time. The amendments will be published on the Website. We therefore advise you to carefully read this privacy statement on a regular basis in order to be fully aware of any amendments.
9. Contacting us
If you have any questions, please contact us at:
Innprove Investments B.V. Hengelosestraat 500 7521 AN Enschede The Netherlands E-mail: email@example.com
Registration chamber of commerce: 73803820 VAT number: NL859669762B01