OVORO CRYPTO-ASSET SERVICE PRIVACY POLICY

With this Privacy Policy we provide you information on why and how we process your Personal Data in connection to the Ovoro Crypto-Asset Service (hereinafter “Service”).

The Service consists of providing crypto-asset exchange services and wallet services to Customers.

1. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

The Controller of your Personal Data is Ovoro Oy (business ID:3376649-1), and we are located Lapinlahdenkatu 16, 00180 Helsinki, Finland.
‍
You can reach us via email at: data@ovoro.com.

2. WHAT DEFINITIONS ARE USED IN THIS PRIVACY POLICY?

• AML Act means the Act on Preventing Money Laundering and Terrorist Financing of Finland (444/2017).
• Crypto-Asset means a digital representation of a value or of a right that is able to be transferred and stored electronically using distributed ledger technology or similar technology (e.g. bitcoin and ether).
• Controller means a party that is in charge of the Personal Data processing activities.
• Customer means our customer who accesses our service in order to purchase Crypto-Asset collections that contain one or more Crypto-Assets pre-selected by the Company (“Bundles”).
• Data Subject is a term for a human being in accordance with data protection laws.
• GDPR means the General Data Protection Regulation (EU) 2016/679.
• Legal basis for processing means the legal basis with which the Controller processes Personal Data of a Data Subject. Article 6 of the GDPR contains provisions on legal basis for processing.
• Personal Data means any data concerning a Data Subject or data with which a Data Subject can be identified with.
• Privacy Policy means a data protection document that has been drafted according to Articles 13 and 14 of the GDPR, and with which the Controller may inform its Data Subjects of the ways their Personal Data is processed.
• Processor means a party that processes Personal Data for and on behalf of the Controller.
• Purpose for processing means the reason why the Controller processes Personal Data of a Data Subject.

3. WHY DO WE PROCESS YOUR PERSONAL DATA?

We process Personal Data to be able to provide our Service to our Customers, comply with our legal obligations under the AML Act as well as enhance and develop our Service.
‍
Our legal basis for processing Personal Data depends on the purpose for which we process Personal Data. We use as a legal basis

(i) our contractual obligations when we provide our Service to our Customers,
(ii) our legal obligations when complying with the AML Act and
(iii) our legitimate interests when enhancing and developing our Service.

In our Personal Data processing activities, we process names, contact information, data related to the use of our Service and data we are required to process under applicable laws of our Customers and their representatives.  

4. FROM WHERE DO WE COLLECT YOUR PERSONAL DATA?

We collect your Personal Data from you when you interact with us in regard to our Service, from digital services we use from time to time (e.g. compliance tools for anti-money laundering purposes) and from public sources (e.g. official registries such as trade registry).

5. DO WE DISCLOSE OR TRANSFER YOUR PERSONAL DATA?

As a general rule, we will not disclose your Personal Data to third parties. However, if we are required by law or governmental authorities to disclose your Personal Data, we will assess the legality of such disclosure on a case-by-case basis.

We do share, i.e. transfer your Personal Data to others as part of our normal business activities when using various digital services. For example, we use the following digital services provided by data processors, which involve the processing of Personal Data:
‍
- data storage services (e.g. cloud services),
- communication services (e.g. e-mails) and
- compliance tools.

6. DO WE PROCESS YOUR PERSONAL DATA OUTSIDE THE EU AND THE EEA AREA?

Your Personal Data may be processed outside the EU and the EEA area. In these situations, we ensure an adequate level of data protection, for example, through standard contractual clauses, adequacy decisions, and other similar arrangements.

7. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We retain Personal Data for

(i) at least five (5) years after the end of customer relationship,
when processing Personal Data to ensure compliance with the AML Act, and

(ii) as long as it is necessary to fulfill the purpose of data processing,
when we process Personal Data for the purposes of enhancing and developing our Service.

8. WHAT DATA PROTECTION RIGHTS DO YOU HAVE?

You may have the right to use the below listed data protection rights under the GDPR:

• Right to inspect (art. 15)
• Right to rectify (art. 16)
• Right to erasure (art. 17)
• Right to restriction of processing (art. 18)
• Right to data portability (art. 20)
• Right to object; especially when processing Personal Data based on legitimate interests (art. 21)
• Right to not be subjected to automated individual decision-making, including profiling (art. 22)

If you would like to use your rights or inquire something about data protection, please be in touch via email (see contact information from Section 1).

You may also have a right to lodge a complaint with the data protection authorities, if you think that the processing of your Personal Data infringes data protection laws. In Finland, the data protection authority is the Data Protection Ombudsman.

9. CAN THIS PRIVACY POLICY BE AMENDED?

We may unilaterally amend this Privacy Policy. We update the Privacy Policy as necessary, for example, when there is a change in legislation.

Amendments to this Privacy Policy will take effect immediately when we post an updated version on our website. If we make significant changes to the Privacy Policy, or if there is a significant change in the way it is used, we will notify the Data Subjects.

(Last update 21.2.2024)