EFFECTIVE SEPTEMBER 24, 2021
When you access the Site, you will be greeted by a home page (the “Home Page”) listing the various services CoinFlip offers.
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 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.
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;
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.
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 conduct user surveys and questionnaires; and
to comply with Applicable Law.
How We Share Personal Data
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.
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.
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.
In particular, the Site uses:
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.
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
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.
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.
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].
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 privacy[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.
“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
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.