Privacy Policy

Date: September 16, 2022 Volven AS ("Volven", "we", "our" or "us") collects information about you to provide the Services (as defined in the Terms of Service) (collectively, the “ Services ”) to you, to protect our legitimate interests, to analyze and improve our Services, to communicate with you, and to comply with our legal and regulatory obligations. This Privacy Policy (“Privacy Policy”) covers our treatment of the personally identifiable information that we gather when you access or use our Services ("Personal Data"). From time to time, we may revise or amend this Privacy Policy to reflect changes in law, our Personal Data collection and use practices, the features on the Services, or advances in technology. This Privacy Policy does not cover the practices of entities we do not own or control, or people we do not manage. Our Privacy Policy applies when accessing and using the Services, but excludes any products, applications or Services that have separate privacy policies which do not incorporate this Privacy Policy. For the purposes of data protection laws of the European Union, and other relevant jurisdictions where Users are located (“Data Protection Laws”), Volven is a data controller (i.e., the company who is responsible for, and controls the processing of, your Personal Data). The access and/or use of our Services implies acceptance of this Privacy Policy as well as the conditions and provisions included in the Terms of Service. The terms used in this Privacy Policy shall have the same meanings as in the Terms of Service except as otherwise provided herein.
  1. Definitions
    1. Application: A desktop and mobile application developed by Volven that enables online trading of Digital Assets made available for download through Volven's Services.
    2. GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
    3. Website: The website operating at https://volven.io/ together with subpages;
  2. Personal Data collected when registering an Account
    1. When gaining access or using our Services, we may collect your Personal Data. The information we may collect is as follows:
      1. When initiating a process of registering an Account and becoming a User, we may collect your identification information such as first and last name, date of birth, phone number, email, a copy of your government issued photo ID (e.g. a passport copy) and other information necessary to verify your identity to comply with our regulatory obligations under financial laws;
      1. Corporate information: If you are a representative of a legal person with legal capacity to act for the legal person, we may collect information on the legal person such as the legal name of the legal person, company registration number (including tax identification), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners, a power of attorney showing the representative's right to act for the legal person and information on the representative as defined in Section 2.1.1 above;
      2. Financial information: Bank account information, routing number, transaction history, trading data and/or tax identification;
      3. Employment information: Your job title, office location or source of income;
      4. Information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID (that allows us to uniquely identify your browser, mobile device, or your account), and other similar information; and
      5. Correspondence: Information you provide to our support teams.
    1. When communicating with us, we collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, request customer or technical support, apply for a job or otherwise communicate with us.
    2. We may also collect Personal Data where you only partially complete and/or abandon any information inputted through the registering of an Account or our Services and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.
  1. Personal Data collected when using our Services
    1. We may collect certain information automatically when you use our Services. The information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
    2. In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your information with information that other people provide when they use our Services, including information about you when they tag you.
  2. Analytics and Financial Data
    1. We may use third-party tools to monitor and analyze the use of our Services, and to automate certain processes related to the development and operation of our Services:
      1. We may use Google Analytics and/or other service providers to collect information regarding visitor behavior and visitor demographics on our Services.
      2. For more information about Google Analytics, please visit http://www.google.com/policies/privacy/partners/. For more information about Google’s privacy practices, please visit https://policies.google.com/privacy?hl=en. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
    2. We may obtain information about you and your transaction data from other sources, including through third party services to supplement information provided by you. This becomes relevant when you use our Services to make transactions in Digital Assets in trading platforms provided by an Affiliate and the API system in our Services obtains information on transactions you make. This allows us to obtain information on the functionality of our Services, the success of transactions being executed through our Services and to further develop our Services.
  3. How we use your information
    1. To the fullest extent permitted under applicable Data Protection Laws, we use your information to:
  1. Provide any information that you have requested or ordered;
  2. Compare information for accuracy and to verify it with third parties;
  3. Provide, maintain, protect and improve our Services;
  4. Manage, monitor, and administer your use of the Services and provide an enhanced, personal, user experience;
  5. Manage our relationship with you;
  6. Undertake internal testing of the Services or systems to test and improve their security and performance (in these circumstances, we would de-identify any information used for such testing purposes);
  7. Provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
  8. Detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
  9. Contact you to see if you would like to take part in our customer research (for example, feedback on your use of our Services);
  10. Monitor, carry out statistical analysis and benchmarking (provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual);
  11. Deliver advertising, marketing (including but not limited to in-product messaging) or information which may be useful to you;
  12. Deliver joint content and Services with third parties with whom you have a separate relationship (for example, social media providers); and
  13. In addition to the legal and commercial uses listed above, we may be required to provide any and all of your Personal Data to governmental authorities as necessary to comply with the law. To the extent required by Data Protection Laws, or where we have a legitimate and lawful purpose for doing so.
  1. Our Services may contain technology that enables us to:
    1. Check specific information from your device or systems directly relevant to your use of the Services, applications against our records to make sure the Services are being used in accordance with our end-user agreements and to troubleshoot any problems;
    2. Obtain information relating to any technical errors or other issues with our Services;
    3. Collect information about how you use the features of our Services; and
    4. Gather statistical information about the operating system and environment from which you access our Services.
  1. Parties with whom we may share your Personal Data
    1. We may share your Personal Data with:
      1. Third-Party Internet and marketing services vendors such as Active Campaign, Discord, Telegram, Twitter, Amazon, GoogleCloud, Google Analytics, FireBase Cloud, FireBase Hosting;
      2. Government and State Authorities to respond to subpoenas, court orders, legal process, law-enforcement requests, legal claims, or government inquiries and to protect and defend the rights, interests, safety, and security of Volven, our Affiliates, Users, or the public; and
      3. Third-Parties in connection to corporate transactions such as the sale of a website, a merger, consolidation, reorganization, financing, change or control or acquisition of all or a portion of our business by another company or third party, asset sale, initial public offering, or in the unlikely event of bankruptcy or similar proceeding.
  1. Data retention
    1. We will retain your Personal Data for as long as it is necessary for the purposes of performing a contract, comply with our legal and regulatory obligations, and protect our legitimate interests.
  2. Persons who may access your Personal Data
    1. Volven's authorized personnel shall have access to your Personal Data on a need-to-know basis. Our authorized personnel are bound to confidentiality and non-disclosure agreements, and subject to strict company policies related to the access and use of the data.
    2. We may provide your Personal Data to competent authorities upon their request to the extent legally required or to the extent necessary to defend our rights in legal proceedings or investigations.
  3. Data Security
    1. To protect your Personal Data, Volven takes all reasonable precautions and follows the best practices of the industry to prevent the loss, misuse, improper access, disclosure, alteration or destruction of the same.
    1. In addition to the purposes described in this section, we may also use information we gather to deliver targeted and interest-based advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the Services or any other information we have about you (depending on the Services, you may be able to configure these features to suit your preferences).
  1. Legal basis for processing in the EU
    1. In the EU, and in accordance with the GDPR, we collect your Personal Data for the following purposes:
      1. Based on your consent, for marketing purposes, which can be revoked at any time;
      2. Where necessary to perform any contract we enter into, or have entered into, with you to provide access to our Services;
      3. Where necessary for our legitimate business interests (or those of a third party) when your interests and fundamental rights do not override those interests; and
      4. Where we need to comply with a legal or regulatory obligation either in the EU or elsewhere.
    1. You have the following rights:
      1. The right to access your own Personal Data;
      2. The right to have your Personal Data rectified if it is inaccurate or incomplete;
      3. The right to request deletion or removal of your Personal Data where there is no good reason for processing to continue;
      4. The right to restrict processing of your Personal Data where there is no good reason for processing to continue;
      5. The right to data portability to enable moving, copying or transferring of Personal Data from one platform to another;
      6. The right to object to the processing of your Personal Data in certain circumstances; and
      7. Rights relating to profiling and automated decision making resulting from the processing of your Personal Data.
    1. The exercise of these rights is personal and therefore must be exercised directly by the interested party, requesting it directly to Volven, which means that any user, subscriber or collaborator who has provided their data at any time can contact Volven and request information about the data that it has stored and how it has been obtained, request the rectification of the same, request the portability of your Personal Data, oppose the processing, limit its use or request the cancellation of that data in Volven's files.
    2. To exercise the rights of access, rectification, cancellation, portability and opposition, you must send an email to the Data Protection Officer of Volven (contact@volven.net) together with a valid proof of identity such as a Government-issued ID document. The exercise of your rights does not include any Personal Data that Volven is obliged to keep for administrative, performance of contracts, legal or security purposes.
  1. Cookies
    1. Visits to our Website
      1. Cookies are small text files that may be sent to your device (computer, smartphone, etc.) by our Services to register your IP address and movements on the Services. Data obtained from cookies cannot be linked directly to you.
      2. In order to ensure that our Services operate as smoothly as possible and to provide services at the highest level, we may use cookie files (cookies) on our Services. We may also use cookies for marketing purposes.
      3. The purpose of using cookies is to compile statistics to improve and further develop our Services. These statistics can, for example, provide answers to how many people visit our Website, how long the visit lasts, where the user came from and which devices are used. We use Google Analytics (https://www.google.com/analytics/) to analyze the information. Information from this tool is not shared with others. Since IP addresses can be traced back to a specific hardware and thus an individual, this is defined as personal information. We de-identify the information before the information is stored and processed in Google Analytics. De-identifying means that the information we collect cannot be traced back to the individual user. The information collected by Google Analytics is stored on Google’s servers in the United States. This information is subject to Google’s Privacy Policy. (https://www.google.com/intl/en/policies/privacy/).
      4. You decide whether you want to allow the storage of cookies in general. The majority of browsers are set to accept cookies automatically. If you do not want such information to be stored in your browser, go to the settings of the current browser and disable the functionality. The following indicates how to change the cookie settings of the most popular search engines (this may vary depending on the country and browser update):
        1. Google Chrome: Menu > Settings > Show advanced settings > Privacy > Content settings > Cookies – select the appropriate option.
        2. Internet Explorer/Microsoft Edge: Menu > Tools > Internet options > Privacy – select the appropriate option.
        3. Mozilla Firefox: Menu > Options > Privacy > History – select the appropriate option.
        4. Opera: Menu > Preferences > Advanced > Cookies – select the appropriate option.
        5. Safari: Menu > Preferences > Privacy > Cookies – select the appropriate option.
      1. Changing the settings of cookies by restricting their use may affect the functionality of our Website. So please keep in mind that saying no to cookies can lead to the Website not working optimally.
      2. In the case of cookies which are not necessary for the website to function properly, you will be asked for your consent to their use on the first visit. Consent is granted or refused by clicking the appropriate button in the pop-up box.
    1. When using our Services
      1. On our Services, including our Services, and mobile applications, we use cookies for the same reason as stated in Section 11.1.3 above.
  1. Navigation
    1. When accessing and/or using the Services, non-identifying data may be collected, which may include the IP address, geolocation, a record of how Services are used, browsing habits and other data that cannot be used to identify the User.
    2. The Services use the following third-party analysis Services: Google Analytics.
    3. Volven uses the information obtained to obtain statistical data, analyze trends, administer the Services, study navigation patterns and to gather demographic information.
  2. Accuracy and completeness
    1. You agree that the information provided to Volven is correct, complete, accurate and current. You are solely responsible for the correctness of the information you submit when accessing and/or using the Services, indemnifying Volven from any responsibility in this regard.
  3. Acceptance and consent
    1. You declare to have been informed of the conditions regarding processing of Personal Data. You accept and consent to the treatment of the same by Volven in the manner and for the purposes indicated in this Privacy Policy.
    2. In case of incorporation, acquisition, merger or any other causes that will change the Operatorship of the Services, you expressly consent that your Personal Data is transferred by Volven to the new Operator. When and if this occurs, Volven will comply, in any case, with the duty of information to you.
  4. Service Operator
    1. The Services are operated by Volven AS, , a company incorporated and registered at Ruseløkkveien no. 34, 0251 Oslo, Norway, with company registration number 927129132.
  5. Contact
    1. In case you have any questions or complaints about the Privacy Policy, you can contact our data protection officer via email to contact@volven.net. In case your question or complaint is not sufficiently solved by us, you may contact your local data protection authority at datatilsynet.no.