Introduction

Our Privacy Policy explains how your personal data is collected, stored, used, removed and disclosed by Hodlex Ltd. ("Hodlex Ltd", "we" or "us"). The rules of this Privacy Policy apply to information we collect when you use Hodl Hodl platform operated by Hodlex Ltd (“Hodl Hodl” or "Platform").

Please note that any provision of this Privacy Policy may be revised and reissued unilaterally by us without notice at any time. You should visit this page regularly to review the current version of the Privacy Policy, since your continued use of the Platform will be deemed as irrevocable acceptance of any revisions.

By using the Platform, you irrevocably express consent for us to collect, store and use the information you share with us as well as the other information mentioned in this Privacy Policy. Should you not accept this Privacy Policy, or any single rule or rules of it, you shall immediately stop using our Platform and delete your account.

Information We Collect

Hodl Hodl must receive or collect some information to operate, provide, improve, understand, customize, support, and market our Platform, including when you visit, access, register or use our Platform. The types of information we receive and collect depend on how you use our Platform.

Information you provide us when using Hodlex Ltd Platform

• Account Information. You provide your email and basic information (including a nickname and timezone) to create an account on accounts.hodlhodl.com. After account creation, you may also add other information to your account, such as a profile picture and information about yourself.
• Trading Information. Trading information includes information relating to your trades, created advertisements, the value of your trades in terms of both cryptocurrency and fiat, Bitcoin addresses, the price of the cryptocurrency, the currency used, the timestamps that the trades took place, the chat logs of the trade, nicknames of both buyer and seller, the payment method, a record of initiated trades, trade IDs, merchant invoice information (if exists) and other information (if exists).
• Communication Information. Communication information relates to communications. Any communication you have with us may be stored and analyzed, this includes information created through using our Platform, including all communications during a trade with other users and file attachments, communications with customer support, which may happen through support tickets, emails, or the dispute resolution process, or any other communication channel, including all messages and communications with our customer support.
• Information relating to user identity and payment details.  In case of a dispute, you will be obliged to provide us with your ID and account statements etc., which may be required for dispute resolution. The user is also free to verify his or her self on an entirely voluntary basis. The term ID may include: full name, date of birth, country (country of residence and citizenship), and other information. Mandatory ID verification may also take place if we suspect abuse of our Platform such as criminal activity, money laundering or fraud.

Automatically collected information during the use of Hodlex Ltd Platform

• Log records and usage information. We may collect information about your activity when using our Platform, including diagnostics, performance related statistics, and Service related information. Including when you registered to use our Platform, when you most recently updated your information, when you last used our Platform, and which features you use, such as offer creation, API, or engaging in contracts. This also includes information relating to your activity, how you use our Platform, the time, frequency, and duration you use our Platform, how you interact with others while using our Platform, the settings you use when using our Platform, log files, performance logs, diagnostics (such as crashes and website usage statistics) and other reports.
• Connection Information (Device And Location). We may collect device information, and other information relating to your connection when you access and use our Platform, such as your IP and MAC address and related information, browser information, operating system information, and hardware model etc.

Third-Party Information

• Information Others Have Provided About You. Other users or businesses may provide us with information about you, such as your nickname, email, and other information. Users may also inform us that you use our Platform. All users and businesses are required to have legal rights to use, collect, and share your information before sending your information to us.
• Third Parties. Third party service operators may work with us, and we may receive information about you to improve our operations, and to help us provide our Platform, customization, understanding, as well as to provide support, research and conduct surveys, market our Platform, and to understand how people use our Platform, the distribution of our Platform, and to provide infrastructure, delivery, and other systems.

How We Use Information

The following explains how we provide and support our Platform, and use information originating from the choices you make:

• Platform. In order to operate our Platform, provide customer support, improvements, fixes, and the customization of our Platform, we use information that we have access to. We use information about how people use our Platform in order to analyze, evaluate, engage in troubleshooting, and to improve our Platform, as well as for the development, improvement, research, and testing of new features and Platform.
• Security. We investigate all suspicious activity and violations of our terms, to be certain our Platform is being used legally. We verify our users activity and combat conduct that may be deemed harmful. We detect and prevent spam, and any other bad experiences, to promote safety and security both when using and when not using our Platform.
• Communications. We use information to communicate with you regarding our Platform, to send you marketing communications, and to inform you of significant changes or innovations in our Platform, and to send you notifications, including but not limited to contract status updates, new messages from contracts you participate in, and any changes to your account. When you contact us, we use your information to respond to you.
• Location. In order to improve and uniquely tailor our Platform to you, we use location related information such as where you live and your current location, for example, for the purpose of automatically filtering the offer list. IP addresses and other location related information may also be used.
• Promotion. For the purpose of promoting our platform, we may use your offer’s information.

Information You Share With Us

We share the information that you provide by using and communicating through our Platform, to improve our Platform, as well as to understand, support, customize, provide, operate, and market our Platform.

• Public Information. Can be seen by everyone, even if they don't have an account, inside and outside of our Platform. This includes the advertisement of your offer in the list, as well as your profile and trading information. You may manage your profile settings to make only specific information visible to others, as well as make your advertisements private or not visible to others. Also, anybody can see whether or not you are actively using our Platform, and the status of your account. By posting a public offer you automatically grant, represent and warrant that you have the right to grant to us an irrevocable, perpetual, exclusive, fully paid, worldwide license to use, copy, perform, display, and distribute such an offer and to prepare derivative works of, or incorporate it into other works, such personal data.
• Counterparties. People you trade with may store and share your information (such as your contact details, messages, or chat attachments) with others that may or may not use our Platform.
• Third Party Sharing: We do not sell your information, and never will. We do partner with third parties to help use, provide and improve our Platform, which allows us to operate globally. We strictly limit how our partners use and disclose the data we provide. The following are the types of third parties we share information with:
1. When monitoring for and fixing crashes, we use "Sentry" service, your IP address may be included in the error messages.
2. "Google Analytics" service is used for behavioral statistics. Your IP address may be included in the data we provide to Google Analytics, which is used by Google Analytics to understand how you use our Service.
3. We use "AWS" service for storing your personal data.
4. For communications we use "ProtonMail". We may share data with Protonmail that includes your email and nickname.
5. We use "Twitter" service for promotions. We may provide Twitter with data such as your offer information;
6. We use “SendGrid” to send critical notifications and product updates regarding our Platform, informative emails, announcements and marketing emails.

We may provide anonymous data such as usage statistics about the users of our Platform to share our traffic patterns, sales, customers, and other information to potential partners, investors, marketers, other reputable third parties, and for other legal purposes, however none of these statistics will contain your personal data.

We will never share Your IP and/or MAC address and/or any other sensitive information with anyone (even You) if we believe that it can harm our customers or if there is no legal obligation for us to do so.

Our Legal Basis For Processing Information

We process the information we have as described below:

• As required in fulfilling our Terms of Service;
• Consistent with your consent which you can withdraw at any time;
• As required to be in compliance with our legal obligations;
• As it may be necessary to protect your (and others’) interests;
• As for the benefit of the public interest;
• As required to benefit the interests of yourself and others, fulfilling our goal of providing a safe, innovative, and profitable Service for our users and partners, barring these interests being superseded by your rights, freedoms, and personal interests that mandate the utmost protection of your personal data.

Your rights

In this Section, we summarise the rights you have regarding your personal data.

You have the following rights regarding your personal data:

• A right to object to us processing your personal data, citing personal reasons; however, understand that we may still process your personal data if we have lawful grounds to do so, but only if our interests in processing your personal data are not overridden by your rights, interests, or freedoms;
• A right to access the personal data of yours that we hold. You may also receive specific personal data in a machine readable format such as .pdf or .csv;
• A right to transfer your data, if we are in legal accordance of processing your personal data and you consent, and the processing is executed automatically, you are within your rights to be sent your personal data from us in a structured, regularly used machine readable format, only if this would not negatively affect the freedoms and rights of others;
• A right to rectify any inaccuracies in your personal data;
• A right to have specific parts of your personal data erased when it is no longer required for us to process it, if you have withdrawn your consent, objected, if your personal data has been unlawfully processed, and/or if erasing your personal data is a requirement in accordance with a legal requirement;
• A right to be made aware of the logic we use to make automated decisions about you, upon request;
• A right to withdraw consent (if previously given) for processing your personal data. Please note that withdrawing consent does not affect the lawfulness of processing your personal data before the withdrawal. You may withdrawal your consent by emailing ;
• A right to contact your national data protection regulator if you are unaware of your rights, or are concerned about how your personal data is processed;
• A right to file a complaint with the national data protection regulator in your country;
• A right to exercise your rights by emailing us at . We will try to accommodate any request you make in an effort to respect your rights, but please be aware that your rights may not be absolute rights. This means that we are within our rights to refuse your request or may only be able to partially comply;

If you make a request, in respect of your rights, we may ask for clarification about your request. If we believe your requests are unreasonable or repetitive, we do have the right to not respond.

Storing and Deleting Personal Data

We keep your personal data for however long is necessary to provide you with our Platform. We store your personal data for up to 5 years following the deletion of your Account (if applicable) or from the last contact we receive from you. We will delete your personal data when we are not required to process your data. Please be aware that legal and regulatory requirements may require us to store your personal data for a longer period, pursuant to any applicable statutory limitation period.

How We Transfer Data While Operating Global Platform

Hodlex Ltd. information is shared globally, internally within the company, as well as externally with our partners, and with everyone who communicates according to this Privacy Policy. Hodlex Ltd transfers, transmits, stores, and processes information mostly within the European Economic Area, and other countries outside of your country of residence for the purposes described in this Privacy Policy. Transferring data in this manner is required in order to provide you with our Platform as described in our Terms of Services. The European Commission approves the standard contract clauses we use, and we may be reliant upon the European Commission's adequacy decisions about certain countries, as applicable, for data transfers from the European Economic Area to the United States and other countries.

Cookie policy

What Are Cookies?

It’s common for most professional websites to use cookies, as our site does. Cookies are very small files that are temporarily, or permanently, downloaded to your computer, for the sole purpose of improving your experience as a user of the website. Here we describe the purpose of a cookie, which is the information they gather, we also explain how we use this information and why we sometimes need to store these cookies. We also explain how you can prevent these cookies from being stored, however this may limit site functionality or render it unusable.

For more information on cookies you can see the Wikipedia article on HTTP Cookies.

How We Use Cookies

Unfortunately, like many if not most websites, there are no options for disabling cookies, without completely disabling the functionality and usability of the site. Fortunately, our cookies are harmless. So it is recommended that you leave on - all cookies - as they are likely required to provide you with a Service our website provides.

Turning Off Cookies

You can block cookies by changing the settings on your browser (typically located under the privacy settings in your browser). Please be aware that disabling cookies will affect the functionality of our website, and many others that you visit. Disabling cookies usually results in limiting the functionality and features of websites. Therefore, we recommend that you do not disable cookies.

Cookies We Issue

Once you create an account with us, we will use cookies for administration purposes such as managing the signup process, as well as for preventing the abuse & misuse of our Platform. Cookies will usually be deleted when you log out, however, in some cases they remain afterwards, for example, to remember your site preferences for the next time you log in. In other words, once you are logged in, we use cookies to remember your site preferences. Furthermore, cookies prevent you from having to log in every time you visit a new page. These cookies are usually deleted when you log out to ensure you only have access to restricted features and areas when you are logged in. In order to provide you with a great experience on our website, we give you the ability to set your own preferences for how our site runs, whenever you use it. We set cookies so your customizations and preferences are remembered whenever you use a particular page.

Third-Party Cookies

Sometimes we also use cookies from trusted third parties. For now, the third parties are all part of Google company’s services, such as:

• Google Analytics,
• Youtube,
• reCAPTCHA.

For more information on Google Analytics cookies, you can see the official Google Analytics page.

For more information on reCAPTCHA cookies, you can see the Privacy Policy for reCAPTCHA page.

For more information on Google cookies, you can see types of cookies used by Google page.

Contact Information

Hodlex Ltd. is the data controller responsible for your personal data. If you have any questions or requests related to our policies you may contact our data protection office through email: