Privacy & Policy

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Our Company Privacy & Policy

coinfigo takes a comprehensive approach to protecting your investments in crypto assets and commodities .


1.This privacy notice applies to the processing activities performed by Coinfigo to the personal data of its clients, prospective clients, and website visitors. Your privacy is of the utmost importance to us. It is our policy to safeguard the confidentiality of information and respect the privacy of individuals. Please see below for information about how we manage personal data, and for information about your rights with respect to the processing of your personal data.

Data Collection & Use

2. Definitions
The following terms are defined as follows:
2.1 “AML” means anti-money laundering.
2.2 “Digital Asset” means any digital representation of value that may be traded via Coinfigo services, excluding non-fungible tokens.
2.3 “Coinfigo ”, “We”, “Us”, refers collectively to Payward, Inc. and its subsidiaries.
2.4 “Personal data” refers to any information relating to an identified or identifiable natural person, including names, identification numbers, location data, an online identifier, or to one or more factors specific to the physical, economic, cultural or social identity of a natural person.
2.5 "PIL Services" means e-money services. For a full definition, please see Annex I of the Terms of Service here.
2.6 “VASP Services” means exchange between digital assets and fiat currencies; exchange between one or more forms of digital assets; transfer of digital assets, that is to say, conduct a transaction on behalf of another person that moves a digital asset from one digital asset address or account to another; and act as a custodian wallet provider.
3. Your Data Controller
Our products and services are provided through local operating entities that are part of the Coinfigo group of companies. You are contracting with Coinfigo as specified in Section 18 Full Details of Data Controllers.
4. How do we protect personal data?
Coinfigo takes the security of personal data incredibly seriously. Please see here for further detail about our information security practices, and here for general security information.
5. Information we may collect about you
We obtain information about you in a number of ways through your use of our products and services, including through any of our websites, the account opening process, webinar sign-up forms, event subscribing, news and updates subscribing and from information provided in the course of on-going support service communications. In order to open an account with us, you must first complete and submit a “create account” form to us by completing the required information. By completing this form, you are requested to disclose personal data in order to enable Kraken to assess your application and comply with the relevant laws and regulations. The minimum information required for entering into a contract governing your use of our products and services, and for enabling us to comply with our statutory obligations in respect of anti-money laundering and crime and fraud prevention, is biographical information and contact information, verification information, PEP information (defined below), and financial information. Without this information, we cannot commence, or continue to perform our services or provide our products to you.
The information that we collect from you is as follows:
• Full name, residential address and contact details (e.g. email address, telephone number etc.), date of birth, place of birth, gender, citizenship (“Biographical information and contact information”); • Bank account information, wallet addresses, details about your source of funds, assets and liabilities, and information relating to economic and trade sanctions lists (“Financial information”); • Trading account balances, trading activity (such as whether you participate in Coinfigo VIP program, and custodial activity), your inquiries and our responses (“Trading information”); • Information on whether you (or someone close to you) holds a prominent public function (“PEP information”); • Verification information, which includes information necessary to verify your identity such as a passport, driver’s licence, selfie photos / videos, login credentials or Government-issued identity card (“Verification information”); • Other personal data or commercial and/or identification information – Information we, in our sole discretion, deem necessary to comply with our legal obligations under various AML obligations, such as under the European Union’s 5th AML Directive and the U.S. Bank Secrecy Act (“Other information”).

6.Information we collect about you automatically:
• Browser information – Information that is automatically collected via analytics systems providers from your browser, including your IP address, domain name, any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform (“Browser information”); • Log information – Information that is generated by your use of Kraken-branded websites, applications, services, or tools operated by Coinfigo that is automatically collected and stored in our log records. This may include device information such as device identifier, device operating system and model, device storage, Media Access Control (MAC) address and Subscriber Identity Module (SIM) information, signals relating to user behaviour and device interaction, battery usage, location information, network address, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time, page response times, download errors, length of visits to certain pages, page interaction information such as scrolling, clicks, and mouse-overs, and methods used to browse away from the page (“Log information”). Information we receive about you from other sources. We also receive information about you from third parties such as your payment providers, our service providers assisting with AML, fraud, and security compliance, and through publicly available sources. For example: • The banks you use to transfer money to us will provide us with your basic personal data, such as your name and address, as well as your financial information such as your bank account details; • Your business partners may provide us with your name and address, as well as financial information; • Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our website. • Our service providers may provide us with information relating to fraud, security, sanctions and AML and other risks, for example, confirmation of identity attributes, and information about any attributes linked to such matters. • Credit reference agencies may provide us with your personal data during the credit referencing process. 7.personal data
As part of processing your personal data for the purposes set out above, Coinfigo may disclose your personal data to any members of the Coinfigo company group, and to third parties. For example, Coinfigo may disclose your personal data to any of our service providers and business partners, for business or other legitimate purposes, such as specialist advisors who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, IT, debt-recovery, analytics, research or other services. If Coinfigo discloses your personal data to service providers and business partners, in order to perform the services requested by clients or to comply with our legal and regulatory obligations, such providers and partners may store your personal data within their own systems. We require them to protect the confidentiality of this personal data, and comply with all relevant privacy and data protection laws.
8. Where we store your personal data
Our operations are supported by a network of computers, servers, other infrastructure and information technology, and third-party service providers. We and our third-party service providers and business partners store and process your personal data in the European Union, Japan, the United Kingdom, the United States of America and elsewhere in the world. Courts, law enforcement and security agencies of these jurisdictions may be able to use legal processes to access your personal data.
9. For UK & EEA clients:
Transfers of personal data outside of the European Economic Area (EEA) and the United Kingdom (UK) We may transfer your personal data outside the EEA and UK to other Coinfigo group companies, service providers and business partners. Transfers outside of the EEA or the UK (as appropriate) shall be in accordance with lawful transfer mechanisms. If personal data is transferred to a country which has been found by the European Commission to have an essentially equivalent standard of data protection to the EEA, then Kraken may rely on an ‘adequacy decision’ to transfer that personal data. See herefor a list of countries with adequacy decisions. If personal data is transferred from the EEA or UK to the US, we may rely on standard contractual clauses. 10. Privacy when using digital assets and blockchains Your use of digital assets may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to re-identification of transacting individuals and the revelation of personal data, especially when blockchain data is combined with other data. As blockchains are decentralized or third-party networks which are not controlled or operated by Coinfigo and, we are not able to erase, modify, or alter personal data on such networks. 11. Data retention
When personal data is no longer necessary for the purposes for which it may lawfully be processed, we will remove any details that will identify you, or we will securely destroy the relevant records. We may need to maintain records for a significant period of time after you cease being our client for legal or regulatory reasons, for example when we need to retain information to help manage a dispute or legal claim.
Additionally, we are subject to certain anti-money laundering laws which may require us to retain the following for a period (e.g., 5 years) after our business relationship with you has ended:
• A copy of the records we used in order to comply with our client due diligence obligations; • Supporting evidence and records of transactions with you, and your relationship with us. If you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications. We may keep your personal data for longer than 5 years if we cannot delete it for legal, regulatory, or technical reasons.

Data Security

14. Changes to this privacy notice
Our privacy notice is reviewed regularly in light of new regulations, technologies, and any changes to our business operations. Any personal data we process will be governed by our most recent privacy notice. We will update the “Last updated” date accordingly at the beginning of this privacy notice. Please review this privacy notice from time to time. We will announce any material changes to this privacy notice on our website.

15. Our products and services are not available to childre:
Our products and services are not directed to persons under the age of 18 (herein, “Children”, “Child”) and we do not knowingly collect personal data from children. If we learn that we have inadvertently processed personal data from a child, we will take legally permissible measures to remove that data from our records. Coinfigo will require the child user to close his or her account and will not allow the use of our products and services. If you are a parent or guardian of a child, and you become aware that a child has provided personal data to us, please contact us at

16. Contact information:
Any questions, complaints, comments and requests regarding this privacy notice are welcome and should be addressed to
. You can also contact our Data Protection office support at