Date: November 28, 2022
Volven AS ("Volven
" 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
we gather when you access or use our Services ("Personal Data
practices of entities we do not own or control, or people we do not manage.
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
Service except as otherwise provided herein.
- Application: A desktop and mobile application developed by Volven that enables online trading of Digital
Assets made available for download through Volven's Services.
- 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).
- Website: The website operating at https://volven.io/ together with subpages;
- Personal Data collected when registering an Account
- When gaining access or using our Services, we may collect your Personal Data. The information we may
is as follows:
- 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;
- 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;
- Financial information: Bank account information, routing number, transaction history, trading
data and/or tax identification;
- Employment information: Your job title, office location or source of income;
- 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
- Correspondence: Information you provide to our support teams.
- When communicating with us, we collect personal information from you such as email address, phone
mailing address when you request information about our Services, request customer or technical support,
apply for a job or otherwise communicate with us.
- We may also collect Personal Data where you only partially complete and/or abandon any information
through the registering of an Account or our Services and/or other online forms and may use this
to contact you to remind you to complete any outstanding information and/or for marketing purposes.
- Personal Data collected when using our Services
- We may collect certain information automatically when you use our Services. The information may include
Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile
and other unique identifiers, details about your browser, operating system or device, location
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
and other devices.
- In addition, we may automatically collect data regarding your use of our Services, such as the types of
you interact with and the frequency and duration of your activities. We may combine your information
information that other people provide when they use our Services, including information about you when
they tag you.
- Analytics and Financial Data
- We may use third-party tools to monitor and analyze the use of our Services, and to automate certain
related to the development and operation of our Services:
- We may use Google Analytics and/or other service providers to collect information regarding
and visitor demographics on our Services.
- 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.
- 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
of our Services, the success of transactions being executed through our Services and to further develop
- How we use your information
- To the fullest extent permitted under applicable Data Protection Laws, we use your information to:
- Provide any information that you have requested or ordered;
- Compare information for accuracy and to verify it with third parties;
- Provide, maintain, protect and improve our Services;
- Manage, monitor, and administer your use of the Services and provide an enhanced, personal, user
- Manage our relationship with you;
- 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
- Provide you with any information that we are required to send you to comply with our regulatory
or legal obligations;
- 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);
- Contact you to see if you would like to take part in our customer research (for example,
feedback on your use of our Services);
- 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);
- Deliver advertising, marketing (including but not limited to in-product messaging) or
information which may be useful to you;
- Deliver joint content and Services with third parties with whom you have a separate relationship
(for example, social media providers);
- 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.
- Our Services may contain technology that enables us to:
- 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;
- Obtain information relating to any technical errors or other issues with our Services;
- Collect information about how you use the features of our Services;
- Gather statistical information about the operating system and environment from which you
access our Services.
- Parties with whom we may share your Personal Data
- We may share your Personal Data with:
- Third-Party Internet and marketing services vendors such as Active Campaign, Discord, Telegram,
Twitter, Amazon, GoogleCloud, Google Analytics, FireBase Cloud, FireBase Hosting;
- 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;
- 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.
- Data retention
- We will retain your Personal Data for as long as it is necessary for the purposes of performing a
comply with our legal and regulatory obligations, and protect our legitimate interests.
- International data transfers
- We may transfer your Personal Data to third parties outside the EU/EEA assuming an adequate level of
has been put in place to ensure that your Personal Data is treated by those third parties in a way that
consistent with and which respects the GDPR. In particular, we may transfer your Personal Data outside
based on adequacy decision by the Commission or appropriate safeguards such as standard data protection
adopted by the Commission.
- Persons who may access your Personal Data
- 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.
- 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.
- Data Security
- 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
- 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).
- Legal basis for processing in the EU
- In the EU, and in accordance with the GDPR, we collect your Personal Data for the following purposes:
- Based on your consent, for marketing purposes, which can be revoked at any time;
- Where necessary to perform any contract we enter into, or have entered into, with you to provide
access to our
- Where necessary for our legitimate business interests (or those of a third party) when your
fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation either in the EU or elsewhere.
- You have the following rights:
- The right to access your own Personal Data;
- The right to have your Personal Data rectified if it is inaccurate or incomplete;
- The right to request deletion or removal of your Personal Data where there is no good reason for
- The right to restrict processing of your Personal Data where there is no good reason for
processing to continue;
- The right to data portability to enable moving, copying or transferring of Personal Data from
one platform to
- The right to object to the processing of your Personal Data in certain circumstances;
- Rights relating to profiling and automated decision making resulting from the processing of your
- 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
- To exercise the rights of access, rectification, cancellation, portability and opposition, you must send
an email to the Data Protection Officer of Volven ([email protected]) 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.
- Visits to our Website
- 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.
- In order to ensure that our Services operate as smoothly as possible and to provide services at
- The purpose of using cookies is to compile statistics to improve and further develop our
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
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
- 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):
- Google Chrome: Menu > Settings > Show advanced settings > Privacy > Content
settings > Cookies –
select the appropriate option.
- Internet Explorer/Microsoft Edge: Menu > Tools > Internet options > Privacy –
select the appropriate
- Mozilla Firefox: Menu > Options > Privacy > History – select the appropriate
- Opera: Menu > Preferences > Advanced > Cookies – select the appropriate option.
- Safari: Menu > Preferences > Privacy > Cookies – select the appropriate option.
- Changing the settings of cookies by restricting their use may affect the functionality of our
please keep in mind that saying no to cookies can lead to the Website not working optimally.
- In the case of cookies which are not necessary for the website to function properly, you will be
your consent to their use on the first visit. Consent is granted or refused by clicking the
appropriate button in
the pop-up box.
- When using our Services
stated in Section 11.1.3 above.
- When accessing and/or using the Services, non-identifying data may be collected, which may include the
address, geolocation, a record of how Services are used, browsing habits and other data that cannot be
identify the User.
- The Services use the following third-party analysis Services: Google Analytics.
- Volven uses the information obtained to obtain statistical data, analyze trends, administer the
study navigation patterns and to gather demographic information.
- Accuracy and completeness
- You agree that the information provided to Volven is correct, complete, accurate and current. You are
responsible for the correctness of the information you submit when accessing and/or using the Services,
Volven from any responsibility in this regard.
- Acceptance and consent
- You declare to have been informed of the conditions regarding processing of Personal Data. You accept
consent to the treatment of the same by Volven in the manner and for the purposes indicated in this
- In case of incorporation, acquisition, merger or any other causes that will change the Operatorship of
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.
- Service Operator
- The Services are operated by Volven AS, , a company incorporated and registered at Ruseløkkveien no. 34,
Oslo, Norway, with company registration number 927129132.
officer via email to [email protected]. In case your question
or complaint is not sufficiently solved by us, you
may contact your local data protection