Last updated: March 23, 2023

We at Virsymcoin (the Virsymcoin entities listed in Section 11 below, referred to here as “we”, “us” or “our”) respect and protect the privacy of those who explore our Services (“Users”) and Users who sign up for and access our Services (“Customers”) (together referred throughout this policy as “you” and “your”).

This Privacy Policy describes how we collect, use, and share personal information when you explore, sign up for or access our “Services”, which include the services offered on our websites, including Virsymcoin.com, Virsymcoin.com/exchange, Virsymcoin.com/prime, custody.Virsymcoin.com,  Virsymcoin.com/cloud (each a “Site” and collectively the "Sites") or when you use the Virsymcoin mobile app, the Virsymcoin Card App, Virsymcoin Exchange, Virsymcoin Prime, VSC Wallet, or Virsymcoin Custody application programming interface (“API”) or third party applications relying on such APIs (together, our “Apps”) and related services.

If you reside outside of the UK and the European Economic Area (the “EEA”), accessing and using our Services means that you accept this Privacy Policy and its terms.

It is important that you understand how we use your information. You should read this page in full, but below are the key highlights and some helpful links:

    Our goal is to simplify your crypto experience. If you do not wish for your personal information to be collected, used, or disclosed as described in this Privacy Policy, or you are under 18 years of age, you should stop accessing our Services.

    We collect and use your information in order to provide and improve our Services and your experience, protect the security and integrity of our platform, and meet our legal obligations.

We share your information with other Virsymcoin companies, as well as trusted third parties and service providers, in order to offer our Services and fulfill legal requirements.

HOW WE USE YOUR INFORMATION

We use your personal information to deliver, personalize, operate, improve, create, and develop our Services, to provide you with a secure, smooth, efficient and customized experience as you use them, and for legal compliance, loss prevention, and anti-fraud purposes. Learn more about how we use your personal information and our legal basis for each such data use:

HOW AND WHY WE SHARE YOUR INFORMATION

We work with service providers, partners and other third parties to help us provide our Services, and as a result we need to share certain information with these third parties.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We retain your information as needed to provide our Services, comply with legal obligations, or protect our or others’ interests. While retention requirements vary by country, we maintain internal retention policies on the basis of how information needs to be used. This includes considerations such as when the information was collected or created, whether it is necessary in order to continue offering you our Services, whether we are required to hold the information to comply with our legal obligations, including AML/KYC compliance or other financial regulatory obligations, or information preservation requirements. We also keep certain information where necessary to protect the safety, security and integrity of our Services, Customers, and Users.

We retain biometric information (as part of our retention of Supplemental Identification Information) for the period required for financial regulatory compliance or otherwise as required by applicable law. Our third-party identity verification service providers retain this information for as long as set out in their applicable notices/policies.

CHILDREN'S PERSONAL INFORMATION

The Sites and Services are not directed to persons under the age of 18, and we do not knowingly request or collect any information about persons under the age of 18. If you are under the age of 18, please do not provide any personal information through the Sites or Services. If a User or Customer submitting personal information is suspected of being younger than 18 years of age, Virsymcoin will require the relevant Customer or User to close his or her account, and will take steps to delete the individual’s information as soon as possible.

INTERNATIONAL TRANSFERS

To facilitate our global operations, Virsymcoin, its Affiliates, third-party partners, and service providers may transfer, store, and process your personal information throughout the world, including Ireland, Germany, Singapore, the UK, the US, and the Philippines. See here for more information.

If you reside in the EEA, Switzerland, or the United Kingdom, we rely upon a variety of legal mechanisms to facilitate these transfers of your personal information (collectively, “European Personal Data”).

    We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate the international and onward transfer of European Personal Data to third countries, including from our EU operating entities to Virsymcoin, Inc. in the United States. For a copy of the Standard Contractual Clauses, please contact dpo@Virsymcoin.com.

We also rely on adequacy decisions from the European Commission where available and exemptions provided for under data protection law. For example, because Virsymcoin operates and provides its  Services globally, we need to share information with our Affiliates and to data centers outside the EEA in order to develop, offer, and improve our Services (Article 49(1)(b) GDPR). In addition, we may rely on certain exemptions for sharing personal information with law enforcement outside of the EEA in emergency situations (Article 49(1)(f) GDPR).

CHANGES TO THIS PRIVACY POLICY

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. We post any changes we make to our Privacy Policy on this page and, where appropriate, we will provide you with reasonable notice of any material changes before they take effect or as otherwise required by law. The date the Privacy Policy was last updated is identified at the top of this page.

We may provide additional "just-in-time" disclosures or information about how we collect or use your information in the context of specific Services; these in-product notices may supplement or clarify our privacy practices or may provide you with additional choices about how we use your information.