Privacy Policy

This is the privacy policy (the “Privacy Policy”) of GPD Holdings LLC DBA CoinFlip, CF Preferred LLC, CoinFlip Canada Inc. DBA CoinFlip, and their affiliated companies (collectively, “CoinFlip”). This Privacy Policy describes our data practices regarding Personal Information (defined below). This Privacy Policy also describes your data protection rights, including your right to object to some data practices regarding Personal Information. This Privacy Policy applies to Personal Information collected through our website, located at coinflip.tech (the “Site”), mobile application (“the “App”), or through our Bitcoin ATMs (collectively, the Site, the App and Bitcoin ATMs are the “Services”). This Privacy Policy does not apply to any Personal Information collected by third party websites or apps not operated by CoinFlip.

When you access the Site, you will be greeted by a home page (the “Home Page”) listing the various services CoinFlip offers.

From the Home Page, you will have the option to select a specific service, and the Site will direct you to a webpage with specific information regarding that service. By accessing the Site, including the Home Page and any subpages, and/or using our Services, you are consenting to our use of your Personal Information in accordance with this Privacy Policy. Further, your access to and use of the Services is subject to the CoinFlip Terms of Service located at coinflip.tech/terms/terms-of-service.

Information CoinFlip Collects About You

Personal Information You Provide

We use the term “Personal Information” to mean any information that could be used to identify you, including your name, address, email address, birth date, financial information, cell or land-line phone number, or any combination of information that could be used to identify you.

When you interact with our Site, App, or Bitcoin ATM, we collect Personal Information that you choose to share with us. The Personal Information that we collect can vary depending on which Coinflip service you utilize:

• When you interact with one of our physical ATM machines, we collect your name, phone number, and a picture of you for all transactions. Depending on the amount of the proposed transaction, we may collect additional Personal Information about you, such as a selfie image, your government ID/driver’s license, Social Security number, and a second form of ID. You will be prompted for such Personal Information depending on the size of the transaction. If you seek to apply to host an ATM in your business, we ask you to provide Personal Information such as your name and phone number, as well as information about your store.

• When you interact with the CoinFlip Trade Desk, we collect your name, phone number, and a picture of you, which may include facial recognition software and other biometric data. Depending on the amount of the proposed transaction, we may collect additional Personal Information about you, such as a selfie image, your government ID/driver’s license, Social Security number, and a second form of ID. You will be prompted for such Personal Information depending on the size of the transaction

• When you choose to onboard as a counterparty through our Site for cryptocurrency trading services, you are required to provide us with your full name, email address, gender, residential address, birth date, phone number, country of residence and nationality, employment information and status, national and governmental identification information, and financial and banking details, including any joint account holders and people appointed to act on your behalf. CoinFlip uses this information to undertake anti-money laundering and fraud prevention activities and know your customer reviews. If you do not provide Personal Information that we tell you is mandatory, it may mean that we are unable to onboard you or provide you with services/perform all our obligations under our agreement with you. If you give us Personal Information about other people (such as joint account holders), you confirm that they are aware of the information in this Privacy Policy about how we will use their Personal Information, including but not limited to use of their Personal Information to provide services or, if asked, to share such information with third parties (e.g. to provide payment initiation). Once you have been onboarded as a counterparty, CoinFlip will continue to use this information as necessary to effect transactions with you. We also obtain data about you from other sources, including identity verification services, fraud prevention agencies, websites and other publicly accessible information about you. We will also receive data you submit to us through third-party websites.

• When you contact us on the Site, or through social media websites, with a question, a comment, or to sign up to receive communications about CoinFlip and its products and services from us, you will be asked to provide your name and email address. You can ask us to stop or start sending you such marketing messages at any time by writing, electronic messaging or calling us.

• When you comment on one of our blogs, you may be asked to provide name and email address, and username information.

The Site also offers you the opportunity to buy Bitcoin and gift cards online. The Bitcoin purchasing page on our Site is powered by Simplex, an online payment processing service. Any Personal Information provided on the “Buy Bitcoin Online” page, such as name, address, and credit/debit card information, goes to Simplex, and is not collected, held or maintained by CoinFlip. Similarly, the “Buy Giftcards” portion of the Site is powered by eGifter. Any Personal Information provided to purchase gift cards, such as name, address, and credit/debit card information, goes to eGifter and is not collected, held or maintained by CoinFlip.

We have structured our Site so that, as a casual site visitor, you may come to our Site and review selected information about our Services without registering. However, if you wish to use certain Services, you may be asked to create an account, which will require you to provide certain additional Personal Information. Similarly, you will be asked to provide certain additional Personal Information if you wish to contact us through the Site.

Automatically-Collected Information

Even if you do not register for an account on the Site, we may collect certain information automatically. For example, we may automatically receive and record in our system the following information:

• your internet protocol (IP) address and location;

• referrer addresses;

• the type and version of your web browser;

• device identifiers including mobile advertising identifiers;

• your operating system; and

• information from your digital services.

We also record page views (hit counts) and other general statistical and tracking information. We use this data to help us administer and operate our Site, to better understand how our users access and interact with the Site, and for security and monitoring purposes. We may also collect information to meet our regulatory obligations; for example we may identify your IP address in order to ascertain and verify your residency status.

We may send email messages that use a “click-through URL” linked to content on our Site. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked, simply do not click text or graphic links in the email.

Location Data.

We may collect your location information through our mobile applications by capturing the location (e.g. latitude/longitude) of your mobile device. If you have given the app permission to access your location, we may collect your device’s location even if you are not using the Service and store your location history. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to restrict the app’s access to your location data. Geolocation data may be used to enhance the Services, for example to offer additional functionality and information regarding your location in connection with the location of CoinFlip properties.

How We Use Your Personal Information

We use your Personal Information for the following business purposes:

• to process transactions that you have authorized us to make;

• to facilitate your activities with respect to our Site;

• to contact you regarding administrative issues, such as questions about your specific request, or otherwise respond to your comments or requests;

• to verify and authenticate your identity, to help us ensure that the individuals who use the Site and Services are who they claim to be;

• to prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities, including, for example, activities prohibited by the Anti-Money Laundering Act;

• to help us operate our Site;

• to deliver notices regarding your account;

• to send you information we believe is relevant to you, such as news, bulletins, marketing materials, or other information;

• to enforce this Privacy Policy and our Terms of Use;

• to conduct user surveys and questionnaires; and

• to comply with Applicable Law.

We use aggregated information to analyze the effectiveness of our Site, to improve our Services, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our Services and the characteristics of visitors at our Site, and may share aggregated information with third parties, including advertisers. We may collect aggregated information through features of the software that supports our Services, through cookies, and through other means described in this Privacy Policy.

To enable us to better understand the characteristics of our customers and/or to provide services tailored to your needs, we may combine the Personal Information a customer provides with certain automatically-collected information that would not otherwise be personally identifiable. If we combine or link any automatically-collected, non-individually identifiable information with your Personal Information, the resulting combination will be treated as Personal Information under this Privacy Policy.

How We Share Personal Data

We do not disclose your Personal Information to unaffiliated third parties except as provided in this Privacy Policy, as follows:

Service Providers. To assist us in running our business and to perform certain services and functions, your Personal Information may be disclosed, stored, and/or transferred (or otherwise made available) to third-party providers of services such as identification and background checks, cloud-based information hosting and maintenance, website hosting, record keeping, payment processing, transfer agent, email communication and customer support services, analytics, marketing, and advertising service providers, and to exchanges, trading platforms, and financial institutions. For example, we share Personal Information with identity verification providers to help us verify that people using the Services are who they say they are. We use Tawk.to and Aircall for our customer support functions and share Personal Information with them as necessary to carry out their services to us. We use Facebook and Instagram to track visits to our Site. These examples are not exhaustive and we may use other vendors over time as well to help us run our business and provide services to you.

Affiliates. We reserve the right to share certain Personal Information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with CoinFlip. For example, the entities that run CoinFlip’s ATM business, GPD Holdings LLC and CoinFlip Canada Inc. DBA CoinFlip, may share Personal Information with the entity that runs CoinFlip’s OTC trading business, CF Preferred LLC. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.

For Legal and Compliance Reasons. We and our service providers may share your Personal Information to the extent we reasonably believe we are required to do so by law or to comply with legal or regulatory requirements, such as a warrant, subpoena, or other court order, or to protect against fraud, illegal activity, or as otherwise required or permitted by applicable domestic or international laws or legal processes. Your Personal Information may also be disclosed where necessary for the establishment, exercise, or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

In Connection with a Corporate Transaction. Your Personal Information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of CoinFlip or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship. Your Personal Information may also be one of the transferred assets as part of the transaction or bankruptcy. We may also share your Personal Information in the diligence process or to otherwise facilitate any such transaction, and with individuals assisting in the transaction or in connection with a bankruptcy.

For Safety & Security. We may reveal your Personal Information to third parties, including law enforcement agencies, in order to protect the safety and security of our users or of any third party.

Electronic Fund Transfers ("EFTS") and Account Balances. CF Preferred has partnered with financial services software company Sila Inc. to offer you EFTs. When you create a CoinFlip Trade Desk Account with CF Preferred, you might also be prompted to sign up for a Sila Account. You authorize CF Preferred to share your identity and banking information with Sila Inc. to open and support your CoinFlip Trade Desk Account. It is your responsibility to make sure the data you provide us is accurate and complete. You must comply with Sila Inc.’s privacy policy (the “Sila Privacy Policy”) when creating or using your CoinFlip Trade Desk Account. The Sila Privacy Policy may be modified from time to time, and the governing version is incorporated by reference into this Privacy Policy. Any term not defined in this paragraph but defined in the Sila Privacy Policy assumes the meaning as defined in the Sila Privacy Policy.

Cookies, Pixel Tags, and Similar Technologies

Our Site uses a technology called “cookies.” A cookie is a small amount of data, often including a unique identifier, which is sent to your browser from a website’s computers and stored on your computer’s hard drive.

We use both “session” cookies and “persistent” cookies, as follows:

Session cookies: We use session cookies to improve navigation on the Site and to collect aggregate statistical information. A session cookie expires when you close your browser. Additionally, If you have registered with the Site, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers) in order to provide personalized services, and (3) will provide us and our service providers with information that we will use to personalize the Site in accordance with your preferences and interests. Because these cookies are strictly necessary to use the Site, you cannot refuse them.

"Persistent" cookies: Persistent cookies are bits of information that are placed on the hard drive of your computer and can remain for extended periods of time. Persistent cookies also enable us to provide enhanced, more personal features (such as showing-hiding notifications), and track and target the interests of our users to enhance the experience on our Site. The types of persistent cookies used on the Site are described in more detail below. You may set your browser so that it does not accept cookies, and you may also use the direct opt-out tools provided by the parties described below. If you do not enable or if you disable cookies, however, you may not be able to access certain personalized features of our Services.

We may also use so-called “pixel tags” - small graphic images (also known as “tracer tags,” “web beacons,” or “single-pixel images”) - to tell us what parts of our Site have been visited or to measure the effectiveness of marketing campaigns on our Site. In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded invisibly on our Site. Pixel tags inform us whether emails have been opened, to help ensure that our messages are of interest to our Registered Users. We may tie the information gathered by pixel tags to our users’ Personal Information, in which case it will be subject to the terms of this Privacy Policy.

In particular, the Site uses:

• Google Analytics, an analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site. The information generated by the cookie about your use of the Site will be transmitted to and stored by Google. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for Site operators and providing other services relating to Site activity and internet usage, including tracking which pages of our Site you visit so we can optimize your experience with our Site. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. We have implemented the IP anonymization feature in Google Analytics which anonymizes your IP address to protect individual privacy. You can opt-out from the collection of this information by Google by downloading and installing a browser plug-in at https://tools.google.com/dlpage/gaoptout. For more information on Google Analytics privacy practices, read here and, for information on Google Analytics cookies expiration, read here.

• Third party advertising cookies and pixels. The ads appearing on this Site, if any, may be delivered to users by third-party advertising companies. You may find more information on what cookies and similar technologies have been set and how to manage and delete them at http://preferences-mgr.truste.com. For more information on advertising cookies, please also consult the Network Advertising Initiative’s online resources at http://www.networkadvertising.org. If you do not want Twitter specifically to show you interest-based advertising on and off Twitter, you can visit your Twitter settings under Personalization and data, or visit the Digital Advertising Alliance’s consumer choice tool at optout.aboutads.info. If you do not want Facebook to show you interest-based advertising, you can visit Facebook settings under Your Ad Preferences on Facebook.

Social Media

We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture and gender) to deliver the content or as part of the operation of the Site, plug-in or application.

Feedback, Questionnaires and Surveys.

Our Site allows site visitors and customers to participate in surveys and questionnaires, which from time to time we may post on the Site. We also encourage our users to provide feedback to us about our Site and our Services. You are free to choose whether you participate in these activities. We may ask that, in addition to providing your responses, you also provide us with your contact information. In these instances, we use any Personal Information you choose to provide to us in connection with these activities for the purposes for which you submit the information.

We aggregate information derived from survey and questionnaire information – with your Personal Information removed – for monitoring or improving the use and appeal of this Site (with no other obligation to you and, specifically, with no obligation to compensate you for these uses). You are not obligated to participate in any of these activities and, if you undertake these activities, you will have the ability to opt-out as provided below.

Links to Other Sites

This privacy statement applies only to Personal Information collected by this Site. Our Site may contain content and links to third party websites that are not owned or controlled by CoinFlip. CoinFlip has no control over, does not review and is not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our Site and go to another site. During this process, another entity may collect Personal Information from you, and that collection is subject to the third party’s privacy policy/notice. CoinFlip is not responsible for the privacy practices of such other sites, and we encourage you to be aware when you leave our site and to read the privacy statements of each and every web site that collects Personal Information.

Data Security

We have put in place commercially-reasonable administrative, technical, and physical measures in an effort to prevent unauthorized access to or disclosure of Personal Information, and we take reasonable steps to secure and safeguard this Information against loss, theft, and unauthorized use, disclosure, or modification. With that said, there is no such thing as 100% security of the networks, servers, and databases we operate or that are operated on our behalf. For example, email sent to or from the Site may not be secure. Before submitting any Personal Information via the Site, please be aware of these inherent risks and understand that you do so at your own risk.

Data Retention

We keep your Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so in connection with your account, or as required by law (e.g., for tax, legal, accounting or other purposes), whichever is longer.

Your Choices

In general, you may browse the Site without providing Personal Information. However, if you choose not to provide certain Personal Information through this Site, we may not be able to provide certain services or process certain of your requests. You will not be able to become a customer or use all of the features and products that we offer through this Site.

Depending on the functionality associated with the Site feature you are using, you may be able to update or delete certain of your Personal Information on the Site.

Accordingly, at your request, we will take reasonable steps to remove your Personal Information from our databases. However, please note that:

• we may not be permitted to delete your Personal Information completely, due to IRS and regulatory reporting requirements and data backups and records of deletions;

• if you request deletion of your Personal Information, you may be unable to use certain features of the Site and any associated Services;

• certain of your Personal Information may remain in our databases following the deletion of your account; and

• we may not be able to remove de-identified, anonymous, or aggregate data from our databases.

Any deletion requests may be sent to [email protected].

If you no longer wish to receive marketing emails from us, you can opt out of these communications by clicking on the “unsubscribe” link included in those emails, or by contacting us at [email protected]. Please understand that you will not be allowed to opt-out of transactional notices or other legal and related notices concerning your relationship to the Site or your account.

Children's Privacy

This Site is not directed to children under the age of 18. We do not knowingly seek to collect or maintain Personal Information or other information from children under the age of 18. We will use commercially reasonable efforts to delete any Personal Information or other information later determined to be provided by a child under the age of 18. Use of the Site by children under the age of 18 is not permitted. If you become aware that a minor has provided Personal Information through our Site, please email us at [email protected].

Changes to This Privacy Policy

We reserve the right to alter, modify, update, add to, subtract from or otherwise change this Privacy Policy at any time, which will become effective as of posting on the Site. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and share Personal Information.

Your California Privacy Rights

California Privacy Rights Disclosures

Where provided for by law and subject to any applicable exceptions, California residents may have the right:

• To know the categories of Personal Information that CoinFlip has collected about you, the business purpose for collecting your Personal Information, and the categories of sources from which the Personal Information was collected;

• To access the specific pieces of Personal Information that CoinFlip has collected about you;

• To know whether CoinFlip has disclosed your Personal Information for business purposes, the categories of Personal Information so disclosed, and the categories of third parties to whom we have disclosed your Personal Information;

• To have CoinFlip, under certain circumstances, delete your Personal Information;

• To instruct businesses that sell Personal Information to stop doing so - CoinFlip, however, does not sell Personal Information; and

• To be free from discrimination related to the exercise of these rights.

If you would like to exercise any or all of these rights, you may do so by calling 1-888-974-0194, or emailing us at [email protected]. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

Please contact us with questions or to request access to an alternative format of this Privacy Policy.

“Shine the Light” Law

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for such third parties’ direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. However, CoinFlip does not share your Personal Information with third parties for their direct marketing purposes.

How We Respond to “Do Not Track” Signals

Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Your Vermont Privacy Rights

If you are a Vermont resident, we will not share Personal Information we collect about you with nonaffiliated third parties, except as permitted by law, including, for example, with your consent or to service your account, or for joint marketing. We will not share Personal Information about your creditworthiness with our affiliates or for joint marketing other than as permitted by Vermont law, unless you authorize us to make those disclosures.

Your Canadian Privacy Rights

If you are a Canadian resident, you have the right to access, update and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. Alternatively, you may request access, updating and corrections of inaccuracies in other personal information we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records. Your personal information may be transferred from Canada to the United States. Your personal information may also be maintained and processed by us, our affiliates, and other third-party service providers in the United States or other jurisdictions. In the event that personal information is transferred outside of Canada to the United States or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws. If you do not consent to the storage of your personal information outside of Canada, you are unable to use CoinFlip’s services and should immediately discontinue any transactions.

Updates to the Privacy Policy

We may update this Privacy Policy to reflect changes to our privacy practices. We encourage you to periodically review this page for the latest information on our privacy practices.

Prevailing Language

In the event this document is available in multiple languages, the English version of these Terms represents the understanding of both Parties. Any other version is provided as a translation. In the event of conflict between the two versions, the English version shall be controlling.

Contact Us

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, please contact us at [email protected].