We ask that you please read this Privacy Notice before providing us with any information about you or any other person. If you do not agree to this Privacy Notice and any revisions that may be made to it, you should discontinue your use of this Site and our Services.

We respect your privacy, and we are committed to protecting your personal data.This Privacy Notice tells you about your privacy rights and how the data protection principles set out in the Data Protection Act of the Cayman Islands (“DPA”) protect you.

If you are a resident of the European Union, including Iceland, Liechtenstein and Norway (EU) or resident of the United States (US), please refer to the relevant content below.

Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Notice.

1. Important information and who we are

This Privacy Notice aims to give you information on how we will collect, use, store and transfer your personal data when you visit our Site, or through your use of the Services (see the Glossary) and any data you may provide when you register for or use the Services, sign up for alerts or newsletters, contact us with a question or request for help and/or participate in any renewals, promotions or surveys.

The Site and the Services are not intended for minors below the age of 18 and we do not knowingly collect data relating to minors.

It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice, we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements other policies and privacy notices and is not intended to override them.

As a best practice approach, we usually explain through understandable and common means the terms and conditions of our Services, renewals, promotions or surveys, please read them carefully before submitting your personal data.

Growth Labs, a company incorporated under the laws of the Cayman Islands (“we”, “us” or “Crypto.com”), is the data controller and responsible for the processing of your personal data.

If you have any questions or complaints about this Privacy Notice or our privacy practices, or if you want to exercise your legal rights, please contact us at [email protected].

You have the right to make a complaint to the Cayman Islands Ombudsman (“Ombudsman”) about the way we process your personal data. The Ombudsman is the Cayman Islands supervisory authority for data protection issues. Further details about making a complaint to the Ombudsman are available here: https://ombudsman.ky/make-a-complaint.

We would, however, appreciate the chance to deal with your concerns before you approach the Ombudsman or other relevant authority, so please feel free to contact us in the first instance.

We keep our Privacy Notice under regular review. This version was last updated on the date above written. The Privacy laws around the globe change regularly, please check from time to time for new versions of the Privacy Notice.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The Site and any applicable web browser, smartphone app or application programming interface required to access the Services (“Applications”), may include links to third-party websites, plug-ins and applications ("Third Party Sites"). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these Third-Party Sites and are not responsible for their privacy statements. When you leave our Site or Applications, we encourage you to read the privacy notice of every Third Party Site you visit or use.

2. The data we collect about you

Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). More information could be found here:

We may collect, use, store and transfer different kinds of personal data about you which we have grouped in categories in the table below.

Please note that for the registration and use of the Crypto.com DeFi Wallet App a certain amount of personal data is required. Identity Data, Contact Data and Financial Data will be collected if you connect the Crypto.com DeFi Wallet App with the Crypto.com App. Identity Data, Contact Data and Financial Data will not be transferred from the Crypto.com App to the Crypto.com DeFi Wallet App technically, but all the personal data that we have on file on our systems will be linked.

If you are an EU resident and you have chosen to connect the Crypto.com DeFi Wallet App with the Crypto.com App, click here.

If you are a US resident and you have chosen to connect the Crypto.com DeFi Wallet App with the Crypto.com App, click here.

Category of Personal Data

Specific Pieces of Personal Data

Identity Data

first name,
maiden name,
last name,
username or similar identifier,
title,
date of birth and gender,
biometric information, including a visual image of your face,
national identity cards,
passports, driving licenses or other forms of identification documents.

Contact Data

residents details,
billing address,
delivery address,
home address,
work address,
email address and telephone numbers,
proof of address documentation.

Financial Data

payment card details,
virtual currency accounts,
amounts associated with accounts,
external account details.

Transactional Data

details about payments to and from you,
other details of your transactions that will be available from your address scanning on public explorer.

Technical Data

internet connectivity data,
internet protocol (IP) address,
operator and carrier data,
installation and login data,
device type, category and model,
your Crypto. com DeFi Wallet App address,
browser type and version,
time zone setting and location data,
language data,
application version and SDK version,
browser plug-in types and versions,
operating system and platform,
diagnostics data such as crash logs and any other data we collect for the purposes of measuring technical diagnostics, and
other information stored on the devices you allow us access to when you visit the Site, or use the Services, or the Crypto.com DeFi Wallet App.

Profile Data

password,
requests by you for products or services,
information on whether you have Crypto.com App account and the email associated with your accounts,
your interests, preferences and feedback,
other information generated by you when you communicate with us, for example when you address a request to our customer support.

Usage Data

information about how you use the Site, the Services, mobile applications and other offerings made available by us, including:

device download time,
install time,
interaction type and time,
event time, name and source.

Marketing and Communications Data

your preferences in receiving marketing from us or third parties,

your communication preferences,
your survey responses.

We may also ask you to prove ownership or control of a particular blockchain address. We are required to ask for this information to comply with anti-money laundering and counter-financing of terrorism requirements, and to ensure we safeguard against and report any suspicious activity.

In addition, the DPA also treats certain other categories of personal data as sensitive and accordingly such sensitive data warrants extra protection.

Sensitive data (a.k.a. Special Categories data) includes details about your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning your sex life or sexual orientation, as well as details of criminal records or any proceedings for any offence committed or alleged to have been committed, including the disposal of any such proceedings or any sentence of a court in the Cayman Islands or elsewhere.

We will only collect, use, store and transfer your sensitive data, if we are able to satisfy both the lawful basis requirements (see Section 4 and the Glossary), as well as at least one of the following additional conditions:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

Where we need to collect personal data by law, or under the terms of a contract we have with you (where the personal data is necessary for the performance of that contract), and you refuse to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you Services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

Direct interactions. You may give us your Identity Data, Contact Data and Financial Data by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal data you provide when you:

Automated technologies or interactions. As you interact with us via our Site or Crypto.com DeFi Wallet App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We will also collect Transactional Data. We may also receive Technical Data about you if you visit other websites employing our cookies. On our main website you will be informed about how we use cookies through the Cookie Settings.

Third parties or publicly available sources. We also obtain information about you from third parties or publicly available sources (credit reference agencies, fraud and crime prevention agencies, public blockchain).

4. How we use your personal data

We will only use your personal data when the DPA, the EU General Data Protection Regulation (“GDPR”) (if applicable) or the California Consumer Privacy Act (”CCPA”) (if applicable) allows us to. Most commonly, we will use your personal data in the following circumstances:

Please refer to the Glossary, lawful basis sections to find out more about the types of lawful bases that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. See below for further details on marketing.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Categories of personal information

Lawful basis for processing including basis of legitimate interest

To register you as a new user

Identity Data
Contact Data
Financial Data
Profile Data

Performance of a contract with you

To carry out and comply with anti-money laundering requirements

Identity Data
Contact Data

Compliance with a legal obligation

To process and deliver our Services and any App features to you including to execute, manage and process any instructions or orders, you make

Identity Data
Contact Data
Transactional Data
Technical Data
Marketing and Communications Data

Performance of a contract with you

To prevent abuse of our Services and promotions

Identity Data
Contact Data
Financial Data
Transactional Data
Technical Data
Marketing and Communications Data

Legitimate interests

To manage our relationship with you which will include asking you to leave a review, take a survey or keeping you informed of our company's business and product development

Identity Data
Contact Data
Profile Data
Transactional Data
Marketing and Communications Data

Performance of a contract with you
Consent, if required=

To keep our records updated and to study how users use our products/services

Identity Data
Contact Data
Profile Data
Transactional Data
Marketing and Communications Data

Legitimate interests
Consent, if required

To manage risk and crime prevention including performing anti-money laundering, counterterrorism, sanction screening, fraud and other background checks,detect, investigate, report and prevent financial crime in broad sense,obey laws and regulations which apply to us and respond to complaints and resolving them

Identity Data
Contact Data
Technical Data
Transactional Data

Sensitive Data (a.k.a. Special Categories Data) data that you give us directly or that we receive from third parties and/or publicly available sources:- data which might be revealed by KYC or other background checks (for example, because it has been reported in the press or is available in public registers);- data that is incidentally revealed by photographic ID although we do not intentionally process this personal data

Compliance with a legal obligation
We may also process such data in connection with these purposes if it is necessary for the performance of a contract with you
In addition to our legal obligations, we may process this personal data based on our legitimate interest in ensuring that we are not involved in dealing with the proceeds of criminal activities and do not assist in any other unlawful or fraudulent activities, as well as to develop and improve our internal systems for dealing with financial crime and to ensure effective dealing with complaintsFor Sensitive Data (a.k.a. Special Categories Data) it is necessary for reasons of substantial public interest under the EU Anti-Money Laundering Legislation as the Cayman Islands are subject to the Council Decision 2013/755/EU on the association of the overseas countries and territories with the European Union (‘Overseas Association Decision’).

To enable you to partake in a prize draw, competition or complete a survey

Identity Data
Contact Data
Profile Data
Usage Data
Marketing and Communications Data

Performance of a contract with you
Consent, if required

To gather market data for studying users behavior including their preference, interest and how they use our products/services,determining our marketing campaigns and growing our business

Identity Data
Contact Data
Profile Data
Usage Data
Marketing and Communications Data

Legitimate interests: understanding our users and improving our products and services

To administer and protect our business, our Site and Crypto.com DeFi Wallet App and social media channels including bans,troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

Identity Data
Contact Data
Technical Data
Transactional Data

Legitimate interests: to run our business,provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Identity Data
Contact Data
Profile Data
Usage Data
Marketing and Communications Data
Technical Data

Legitimate interests: to study how users use our products/services, to develop them, to grow our business and to inform our marketing strategy
Consent, if required

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Technical Data
Usage Data

Legitimate interests: to define types of users for our products and services, to keep our website updated and relevant, to develop our business and to form our marketing strategy
Consent, if required

To make suggestions and recommendations to you about goods or services that may be of interest to you

Identity Data
Contact Data
Technical Data
Usage Data
Profile Data
Marketing and Communications Data

Necessary for our Legitimate interests: to develop our products/services and grow our business
Consent, if required

We may use your Identity Data, Contact Data, Financial Data, Technical Data, Transactional Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing. We will use your Marketing and Communications Data for our respective activities.

We will get your express opt-in consent before we share your personal data with any third party for direct marketing purposes.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Further, you can let us know directly that you prefer not to receive any marketing messages by emailing [email protected].

Where you opt out of receiving marketing messages, this will not apply to service messages which are directly related to the use of our Services (e.g. maintenance, change of terms and conditions and so forth).

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services or Site may become inaccessible or not function properly. For more information about the cookies we use, please review the Cookie Preferences.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We may also need to process your data in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving all or a part of our shares, business or assets. This will be based on our legitimate interests in carrying out such transaction, or to meet our legal obligations.

5. Disclosures of your personal data

We may share your personal data with our third-party service providers, agents, subcontractors and other associated organisations, our group companies and affiliates (as described below) in order to complete tasks and provide the Services and use of the Crypto.com DeFi Wallet App to you on our behalf. When using third party service providers, they are required to respect the security of your personal data and to treat it in accordance with the law.

6. International transfers

We may share your personal data within our group. This will involve transferring your data outside the Cayman Islands or the origin of where your data is collected.

Many of our external third parties are based outside the Cayman Islands so their processing of your personal data will involve an international transfer of your data.

Whenever we transfer your personal data out of the Cayman Islands, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

2. Based on our own adequacy assessment regarding the applicable country or territory pursuant to Schedule 1, Part 2(4) of the DPL.

7. Data security

While there is an inherent risk in any data being shared over the internet, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, damaged or accessed in an unauthorised or unlawful way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Depending on the nature of the risks presented by the proposed processing of your personal data, we will have in place the following appropriate security measures:

We have put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a breach where we are legally required to do so.

8. Personal Data Retention

The DPA does not dictate how long any personal data is required to be kept. To determine the appropriate retention period for personal data, we will consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Here are some exemplary factors which we usually consider when determining how long we need to retain your personal data:

Please bear in mind that the right to deletion/erasure of your personal data is not absolute which means that in some circumstances, you can ask us to delete your data: see Section Your Legal Rights for further information. However, when interacting with any blockchain, we may not be able to ensure that your personal data is deleted. This is because blockchains are public decentralised networks and blockchain technology does not generally allow for data to be deleted and your right to erasure may not be able to be fully enforced. In these circumstances, we will only be able to ensure that all personal data that is held by us is permanently deleted.

If you are an EU resident, please make sure that you also review Section 10 below.

9. Your Legal Rights

Under certain circumstances, you have rights under the data protection laws in relation to your personal data:

Please refer to the Glossary at paragraph 10 below for further detail on each of these rights. If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within 30 days. Occasionally, it could take us longer than 30 days if your request is particularly complex or you have made a number of requests, also if more time is required to consult with a third party or other data controller (if needed) before we can reply to your request; In this case, we will notify you and keep you updated.

As per the Guidance of the Ombudsman, for some requests the period for us to reply is 21 days:

The said period could be expanded on the same conditions as described in the first paragraph.

10. EU Residents

As an EU Resident the EU General Data Protection Regulation (“GDPR”) applies to you. In some sections throughout this Privacy Notice we encourage you to check this content as it provides you with certain specificities, please read it carefully.

Processing of your personal data is necessary for reasons of substantial public interest, on the basis of the EU Anti-Money Laundering Legislation as the Cayman Islands are subject to the Council Decision 2013/755/EU on the association of the overseas countries and territories with the European Union (‘Overseas Association Decision’). Hence, we are required to process for instance information from your ID documents including a photographic picture of you.

See also the respective row in the table which describes the purposes for which we will use your personal data.

The statutory period under GDPR for us to reply to a legitimate request is one month. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

If you are an EU resident, you can also lodge a complaint with your local data protection authority. A detailed list is available here:

We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority, so please feel free to contact us in the first instance.

Under the EU Anti-Money Laundering legislation (Anti-Money Laundering Directives 4 and 5) we are obliged to retain your personal data for a period of 5 years after the end of the relationship between us as a company and you as a customer. This period may be further extended in certain cases if so provided by and in accordance with the applicable legislation.

Another example relates to our legitimate business need to prevent abuse of the promotions that we launch. We will retain a user’s personal data for the time of the promotion in order to prevent the appearance of abusive behavior.

We share your personal data within our group. This will involve transferring your personal data outside the European Economic Area (EEA).

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

11. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Services shall have the same meaning as given in Section 3.1 of the Terms and Conditions.