Privacy Policy

Effective: 19 May, 2019.

As the operator of the website ( (Website), our company (Company, we or us) is committed to protecting and respecting your privacy. This policy together with our Website Terms of Use ( sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.

This Privacy Policy applies to information we collect when you access or use our products and services (such as our websites, devices, mobile applications and online services), or when you otherwise interact with us. For the purpose of the 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 (GDPR), the data controller is the Company.

Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By visiting the Website you are accepting and consenting to the practices described in this policy. Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.


Cointorox is a private limited company registered in Estoni, represented by the member of management board Leon Song. To contact us, please email [email protected]


You may be asked to provide your personal information anytime you use or a affiliated company’s Service. and its affiliates may share this personal information with each other and use it consistent with the Privacy Policy. We process personal data about you as necessary to meet our legal and contractual obligations, operate our business, provide the products and services you use or otherwise fulfill the legitimate interests described in the “Uses Made of Information” sections below.

We may collect and process the following data about you:

1. Information you provide us

  1. Subscription. In order to access to newsletter or other materials, you may subscribe with Website. To subscribe with Website, you need to provide us your name and email address.
    • Registration. To increase your rating and reputation in the system, you can create an account with (Account). To create an account, you may need to provide data including your company name, name of the company representative, place of residence of the company representative, website address, email address, phone number or other details to help you with your experience.
    • Your account information. We may ask for your contact information, including your company name, website address, address of the place ● basis for the right of representation; a document, certifying the right of representation. ● details of the actual beneficiary; ● information whether a representative is a politically exposed person; ● website address; ● contact phone number and email address.
    • Communications and customer support. If you contact us, we may receive information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

2. Information we collect about you

2.1. Cookies and other tracking technologies uses cookies. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit.

We may use the following cookies:

  • Strictly necessary cookies. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily;
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. If you wish you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website. Google Analytics We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You can also opt-out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Addon for your current web browser.

2.2. Technical information When you use our Services, regardless of the device you access them from, we may collect information about your engagement with and utilization of our Services, such as blockchain network addresses, transactions performed by using our protocol and all related publicly available information about these transactions, processor and memory usage, storage capacity, navigation of our Services, and system-level metrics. We use this data to operate the Services, maintain and improve the performance and utilization of the Services, maintain reputation scoring service, develop new features, protect the security and safety of our Services and our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. With regard to each of your visits to our Website we may automatically collect the technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information (if applicable), browser type and version time zone setting, browser plug-in types and versions, operating system and platform, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), page response times, download errors, and any information of yours related to contact our customer service team.

3. Information we receive from other sources

This is information we receive about you from public domain, third parties or other websites we operate or the other services we provide. Third parties we work with include: business partners, sub-contractors in technical, payment and delivery services, credit reference agencies, financial services or insurance companies and third party account or platforms, including social media platforms.


We use information held about you in the following ways:

  • To carry out our obligations arising from law;
  • To carry out our obligations arising from any contracts entered in between us;
  • To operate and maintain the Services, for example, to authenticate you when you log in, and to process your transactions;
  • To provide you with the information, products and services that you request from us;
  • To provide you with information about other goods and services we offer that are similar to those that you have already enquired or purchased about;
  • To communicate with you, directly or through one of our partners, including for customer support, to respond to your requests and for assistance and customer service, to provide you with updates and other information relating to the Service;
  • To improve our Website and ensure that content from our Website is presented in the most effective manner for you and for your computer.
  • For compliance purposes, in order to comply with any legal obligation, or in order to enforce or apply Website Terms of Use and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others.
  • To administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes or to administer a contest, promotion, survey or other site feature. a. To allow you to participate in interactive features of our service, when you choose to do so; b. As part of our efforts to keep our Website safe and secure; c. To measure or understand the effectiveness of advertising we may serve to you and to deliver relevant advertising to you. We do not: a. sell or trade personal data; b. take any decisions involving the use of algorithms or profiling that significantly affects you.


We may share your personal information with:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
  • Selected third parties including: a) Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you; b) Fraud and crime prevention agencies for the purpose of assessing the risk of crime, fraud and money laundering and this is a condition of us entering into any contract with you. We will disclose your personal information to third parties: 1. As required by law; 2. In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets.
  • If the Company, or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply Website Terms of Use, Cointorox Tokens Purchase Agreement and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others.
  • To meet our legal and contractual obligations.
  • To avoid crime, money laundering and the risk of fraud.
  • To ensure that we have relevant information on persons who are using the website.
  • In order to provide relevant information to regulators, government agencies and banks that may request information about Cointorox.


We do not knowingly collect or maintain personal data on our Website from persons under 13 years of age, and no part of our Website is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Website at any time or in any manner. We will take appropriate steps to delete any personal data of persons less than 13 years of age that has been collected on our Website without verified parental consent upon learning of the existence of such personal data.


In carrying out its services, may transfer your personal data to third countries outside the European Economic Area (EEA). In the event that a jurisdiction is not considered to have an adequate level of privacy protection, will take specific steps to protect your personal data in a manner compatible with EU law. In particular, we may choose to rely on approved Code of Conduct or Standard Contractual Clauses.


We store the information we collect about you for no longer than is necessary for the purposes for which we originally collected it, unless a longer retention period is required or permitted by applicable law and it is in our legitimate business interests to do so. SECURITY Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

More specifically, implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: a) the pseudonymisation and encryption of personal data; b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.


  1. Rights to access your personal data. You have the right to obtain from the confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data.
  2. Right to rectification. You have the right to obtain from the rectification of inaccurate personal data. Taking into account the purposes of the processing, you also shall have the right to have incomplete personal data completed.
  3. Right to restriction of processing. You have the right to obtain from restriction of processing where one of the following applies: a) the accuracy of the personal data is contested by you, for a period enabling the Company to verify the accuracy of the personal data; b) the processing is unlawful and you opposes the erasure of the personal data and requests the restriction of their use instead; c) the Company no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; d) you have filed a claim to processing data, pending the verification whether the legitimate grounds of the Company override yours.
  4. Right to take your data. You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
  5. Right to delete data. You have the right to obtain from the erasure of your personal data without undue delay where it is possible and one of the following applies: a) the personal data is no longer necessary for the purposes for which they were collected or otherwise processed; b) there is no legal ground for the processing; c) you object to the processing of your personal data and there are no overriding legitimate grounds for the processing; d) your personal data has been unlawfully processed; e) your personal data has to be erased due to an EU or EU Member State legal obligation to which is subject; f) the personal data have been collected in relation to the offer of information society services. Where has made your personal data public, it shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform controllers which are processing your personal data, that you have requested the erasure by such controllers of any links to, or copy or replication of, your personal data. Notwithstanding the above, your right to erasure shall not apply to the extent that processing is necessary in certain circumstances set out in the GDPR, and especially: a) for exercising the right of freedom of expression and information; b) for compliance with a legal obligation which requires processing by EU or Member State law to which is subject or for the performance of a task carried out in the public interest; or c) for the establishment, exercise or defence of legal claims.
  6. Right to lodge a complaint. You have a right to lodge a complaint with the supervisory authority of the country in which you reside.


We may revise our Privacy Policy from time to time to reflect changes to our business, services or relevant laws. Any changes we make to our Privacy Policy in the future will be posted on this page with immediate effect from the date of publication and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.


Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to [email protected]