INX Legal

Privacy Policy

The INX Digital Company, Inc and its wholly-owned, separately operated subsidiaries, including INX Digital, Inc. and INX Securities, LLC (collectively, “INX”, “we”, “us”) value the privacy of individuals who visit https://www.inx.co/ and any of our other websites, applications, or services that link to this Privacy Policy (collectively, the “Service”). The Service users (“Users”) to buy, sell or trade cryptocurrencies. This Privacy Policy (“Policy”) is designed to explain how we collect, use, and share information from users of the Service and is incorporated by reference into our Terms of Service.

By agreeing to this Policy in your account setup and through your continued use of the Service, you agree to the terms and conditions of this Policy.

Information We Collect

Information You Provide to Us

We collect any information you provide to us when you use the Service. You may provide us with information in various ways on the Service.

Registration: If you register with us as a User, you are required to provide us with your name and email address and to designate a password. In order to use our cryptocurrency trading venue as a User, we  also require certain information to confirm your identity. For example, Users hoping to trade cryptocurrency in an individual capacity, and not on behalf of a corporation or trust, must provide their full name, social security number, phone number, address, and date of birth. We may also require Users to complete a short questionnaire regarding their interest in specific types of tokens and cryptocurrencies.

Financial Information: Users may buy, sell, or trade cryptocurrencies using traditional fiat currency and/or cryptocurrency. To facilitate these transactions, we may collect necessary financial information, such as your bank’s routing number and your account number.

Communications: If you contact us directly, we may receive additional information about you. For example, when you email our Customer Support Team, we will receive your email address, the contents of a message or attachments that you may send to us, and other information you choose to provide.

Information We Collect Automatically From Your Use of the Service

When you use our Service, we may collect information from you through automated means, such as cookies, web beacons, and web server logs. By using the Service, you consent to the placement of cookies, beacons, and similar technologies in your browser and on emails in accordance with this Policy. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Service.

We may use this information, for example, to ensure that the Service functions properly, to determine how many users have visited certain pages or opened messages, or to prevent fraud. We also work with analytics providers which use cookies and similar technologies to collect and analyze information about use of the Service and report on activities and trends.

If you do not want information collected through the use of cookies, there is a procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.

If, however, you do not accept cookies, you may experience some inconvenience in your use of the Service.

How We Use Your Information

We may use the information we collect:

  • To verify the identity and accreditation status of Users, which may include conducting a soft pull on your credit history, and to facilitate participation in the Service.
  • To operate, maintain, enhance and provide features of the Service, to provide services and information that you request, to respond to comments and questions, and otherwise to provide support to users.
  • To understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, features, and functionality.
  • To contact you for administrative or informational purposes, including by providing customer service or sending communications, including changes to our terms, conditions, and policies.
  • For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest.
  • To personalize your experience on the Service by presenting tailored content.
  • We may aggregate data collected through the Service and may use and disclose it for any purpose.
  • For our business purposes, such as audits, security, compliance with applicable laws and regulations, fraud monitoring and prevention.
  • To enforce our Terms of Service or other legal rights.

How We Share Your Information

We may disclose information that we collect through the Service to third parties in the following circumstances:

  • To credit bureaus and other third parties who provide Know Your Customer and Anti-Money Laundering services, including verifying users as accredited investors.
  • To our third party service providers who provide services such as website hosting, data analysis, customer service, email delivery, auditing, and other services.
  • To a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).
  • If required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our subsidiaries; (f) to protect our rights, privacy, safety or property, and/or that of our subsidiaries, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

In addition, we may use third party analytics vendors to evaluate and provide us with information about your use of the Service. We do not share your information with these third parties, but these analytics service providers may set and access their own cookies, pixel tags and similar technologies on the Service and they may otherwise collect or have access to information about you which they may collect over time and across different websites. For example, we use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at How Google uses information from sites or apps that use our services – Privacy & Terms – Google .

We may use and disclose aggregate information that does not identify or otherwise relate to an individual for any purpose, unless we are prohibited from doing so under applicable law.

How Long We Keep Your Information

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


Third Party Services

We may display third-party content on the Service. Third-party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with your viewing of and/or interacting with the third-party content on the Service. This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Service link. The inclusion of a link on the Service does not imply endorsement of the linked site or service by us or by our affiliates.


Security

We use certain physical, organizational, and technical safeguards that are designed to maintain the integrity and security of information that we collect. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee the security of your data. It is important that you maintain the security and control of your account credentials, and not share your password with anyone. In addition, we may offer our users two-factor authentication which is designed to protect their account.


Your Privacy Rights and Choices

You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some or all of the features and functionality of the Service. From time to time, we send marketing e-mail messages to our users. If you no longer want to receive such emails from us on a going forward basis, you may opt-out via the “unsubscribe” link provided in each such email.

Regional Privacy Rights

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please contact us at [email protected] We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/dataprotection/.

California Residents

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

Account Changes and Termination

You may at any time review or change the information in your account or terminate your account by contacting us at [email protected] Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal and regulatory requirements, including those outside of your country of residence.

Use of Service by Minors

The Service is not directed to individuals under the age of eighteen (18), and we request that you not provide personal information through the Service if you are under 18.

International Cross-border Data Transfer

INX uses servers hosted in the United States. Please note that we may be transferring your information outside of your region for storage and processing in the United States and around the globe. By using the Service you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

Updates to this Privacy Policy

We may make changes to this Policy. The “Last Updated” date at the top of this page indicates when this Policy was last revised. If we make material changes, we may notify you through the Service or by sending you an email or other communication. We encourage you to read this Policy periodically to stay up-to-date about our privacy practices. Your use of the Service following these changes means that you accept the revised Policy.

U.S. Consumer Privacy Notice

Companies choose how they share your personal information. Under federal law, that means personally identifiable information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information.

To understand what we do, please carefully read the U.S. Consumer Privacy Notice, available at https://www.inx.co.

Contact us

If you have any questions about this Policy, please contact us at [email protected].