BAXE

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Privacy Policy

About this Privacy Notice

We respect your privacy

At FCG, we believe that the vision of a free, fair and open Internet is worth fighting for. This this is our mission.

We will always be transparent about how we collect and use your personal information and how we protect your privacy, so that you can make informed choices about the information you share with us.

Our approach to privacy is based on the following:

We only collect and use information that we need to provide you with our Services. Without collecting the necessary personal information, we could not do this.

We only share your personal information with trusted third-parties who help us provide you with our Services and the best possible user experience. We always ensure that our partners and service providers take the same level of care with your personal information that we do.

We will never spam you or sell your personal information and will only send marketing messages with your consent. You can unsubscribe from our marketing communications at any time.

Our website and services are not intended for children below the age of 18 years and we do not knowingly collect information relating to children.

Our Privacy Notice below explains in more detail how we handle your personal information, the steps we take to protect your privacy and how you can exercise your individual rights.

Who are we?

This Privacy Notice applies to the processing of personal information by Future Currency Group Pty Ltd A.C.N. 629 537 917 and all its subsidiaries and controlled entities and any entity trading under the FCG brand, or any one of these depending on the context (Collectively known as “FCG”). This notice sets out the steps we take to comply with our obligations under applicable privacy laws, including the Privacy Act 1988 (Cth) (“the Act”) and the General Data Protection Regulation (EU) 2016/679 (“GDPR”)

To find out more about the Act you can contact the Office of the Australian Information Commissioner (“OAIC”) by email at the following address: [email protected]. Specific information about the Australia Privacy Principles (“APP”) may be accessed via the following link: https://www.oaic.gov.au/privacy/australian-privacy-principles/.

FCG collects personal information from you in order to provide you with:

our products, services, including the BAXE mobile application (together the “Services”); and

access to our website www.baxe.com (“Site”).

Data Controller

The data controller of your personal information is the legal entity that determines the purposes, conditions and manner of any processing activities that it carries out. The data controller differs by the location in which you are ordinarily resident or which entered into an agreement to provide Services to you.

Country of ResidenceData ControllerAddress
AustraliaFCG Financial Services Pty LtdLevel 25, Waterfront Place, 1 Eagle Street, Brisbane QLD 4000
EEAFCG Financial Services UABVilnius, Upės str. 23-1

What personal information we collect

Personal information typically means information that identifies or is reasonably capable of identifying an individual, directly or indirectly. It does not include any information that does not reveal your identity (anonymous information). For the purposes of this Privacy Notice, only the definition of personal information from the applicable law in your jurisdiction will apply to you.

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

“Identity Data” means your first and last names, title, date of birth, place of birth, tax identification number, national identity cards, passports, driving licences or other forms of identification documents;

“Contact Data” means your postal address, email address and telephone numbers;

“Financial Data” means your digital currency wallet address;

“Transaction Data” means details about payments to and from us and details of the digital assets you have purchased or sold using our Services.

“Technical Data” means internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site.

“Profile Data” means your information about purchases or orders made by you, your interests, preferences, feedback and survey responses.

“Usage Data” means information about how you use the app the device you use to access our Site and Services.

“Marketing and Communications Data” means your preferences in receiving marketing from us and your communication preferences.

We do not collect any sensitive or special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or any information about criminal convictions and offences without your consent.

Our Services are not directed to children. We do not knowingly collect personal information from children without parental or guardian consent. If we become aware that information about a child has been collected without the appropriate consent or approval, we will take steps to delete such information. If you become aware of any circumstance where we have collected information about a child without the appropriate consent or approval, please contact us using the contact details below.

How we collect your personal information

Directly from you

We may collect your Identity Data, Contact Data, Financial Data and Marketing and Communications Data when you fill in forms or otherwise correspond with us via the app which you use to access our services, via our website, by post, phone, email or otherwise. This includes personal information you provide when you:

  • apply for our services;
  • create an account with us;
  • request assistance from our customer support team;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.

Through automated technologies or interactions

As you interact with our Site and Services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar tracking technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

From third parties or publicly available sources

We will receive personal information about you from various third parties and public sources as set out below:

  • Identity Data, Contact Data, Financial Data and Transaction Data from other companies within our group of companies which you have provided personal information to;
  • Identity Data, Contact Data, Financial Data and Transaction Data from our client who shares your personal information with us so that you can use our services on their behalf;
  • Usage Data from analytics providers;
  • Identity Data, Contact Data and Financial Data from electronic identity verification providers such as IDEMIA and Zencos, in which the data base hosted in the European Union.
  • Identity Data and Contact Data from publicly availably sources.

Anonymity and pseudonymity

You can remain anonymous or use an alias when making a general enquiry about our Services through email, or webchat.

However, we may need you to provide personal information to facilitate our response to your enquiries about our Site and Services and for other purposes as part of us providing you customer support.

How we use your personal information

Our legal basis for processing your personal information

We will only use your personal information when the applicable legislation allows us to. In other words, we have to ensure that we have a legal basis for such use. If you are located in the EEA, UK or Switzerland, we rely on the principles and legal bases provided by the General Data Protection Regulation (“GDPR”) in order to process your personal information.

We typically rely on the following legal bases to process your personal information:

Performance of a contract

We process your information 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. We rely on this basis to provide you with our Services and customer support.

Legitimate interests

We may process your personal information for our legitimate interest, which is to ensure we conduct and manage our business efficiently, so that we are able to provide you with the best and most secure service and experience possible. We make sure we consider and balance any potential impact on you (both positive and negative) and your individual rights before we process your personal information for our legitimate interests.

We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to 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.

Compliance with a legal obligation

We may process your personal information where it is necessary for compliance with a legal obligation that we are subject to (for example, conducting fraud checks and identity verification, and to fulfill our retention obligations).

Consent

Generally, we do not rely on consent as a legal basis for processing your personal information, 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 exercising the “unsubscribe” option in any marketing communication you receive, or by contacting us.

We will not sell, rent, or loan your personal information to any third party, or use your personal information for any purpose not covered in this Privacy Notice without your consent, unless we are legally required to do so.

Purposes for which we will use your personal information

We have set out all of our purposes for processing your personal information, 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 rely on more than one legal basis to process your personal information, depending on the specific purpose for which we are using it. If you’d like to know more about the legal bases we are relying on to process your personal information, you can contact us at any time.

Purpose/Activity

Type of

personal information

Lawful basis for processing including basis of legitimate interest
To register you as a new customer
  1. Identity Data
  2. Contact Data
Performance of a contract with you

To process and deliver your order including:

  1. managing payments, fees and charges
  2. collecting and recovering money owed to us
  1. Identity Data
  2. Contact Data
  3. Financial Data
  4. Transaction Data
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

  1. notifying you about changes to our terms or privacy policy
  2. asking you to leave a review or take a survey
  1. Identity Data
  2. Contact Data
  3. Profile Data
  4. Marketing and Communications Data
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to understand how our customers use our services)
To enable you to partake in a prize draw, competition or complete a survey
  1. Identity Data
  2. Contact Data
  3. Profile Data
  4. Usage Data
  5. Marketing and Communications Data
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to understand how our customers use our services, to develop our services and to grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity Data
  2. Contact Data
  3. Technical Data
  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  2. Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  1. Identity Data
  2. Contact Data
  3. Profile Data
  4. Usage Data
  5. Marketing and Communications Data
  6. Technical Data
Necessary for our legitimate interests (to understand how our customers use our website and services, to develop our website and services, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
  1. Technical Data
  2. Usage Data
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
  1. Identity Data
  2. Contact Data
  3. Technical Data
  4. Usage Data
  5. Profile Data
  6. Marketing and Communications Data
Necessary for our legitimate interests (to develop our services and grow our business)

 

Marketing

We want to ensure you have the ability to choose how your personal information is used, particularly when it is used for marketing and advertising purposes.

Third-party marketing

We will always seek your consent before we share your personal information with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time, by clicking on ‘unsubscribe’ in any marketing messages you receive from us, or by contacting us using the contact details below.

Please note that an opt out or withdrawal of consent to marketing messages will not apply to personal information for which we have another legal basis to process. We may still need to send you communications relating to your purchase and use of our Services and other transactions.

Change of purpose

We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis we are relying on to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with this Privacy Notice, where this is required or permitted by law.

Who do we share your information with and why?

We may share your personal information with the following parties, when necessary for us to achieve the purposes set out in the table above:

Internal Third Parties (including other companies in the same group of companies as FCG, acting as joint data controllers or data processors, based in Lithuania and Australia, who help us to provide you with our Site and Services, IT and system administration services and undertake leadership reporting);

External Third Parties; including:

  • Service providers acting as processors based EEA who provide IT and system administration services;
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Lithuania and the UK who provide consultancy, banking, legal, insurance and accounting services;
  • The Bank of Lithuania and other regulators or authorities acting as processors or joint controllers based in Lithuania who require reporting of processing activities in certain circumstances;
  • Fraud prevention agencies or any other partners which we work with to assist in our aim to prevent fraud; and
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in accordance with this Privacy Notice.

We require all third parties to ensure the security and privacy of your personal information, and to treat it in accordance with the law. Our third party service providers are only permitted to process any personal information we share with them in accordance with our instructions. Our third party service providers will never use your personal information for their own purposes.

International data transfers

From time to time, your personal information will be shared within the FCG group of companies and other third parties we engage to help us provide you with our Services. This will involve transferring your personal information outside the European Economic Area (‘EEA’).

Whenever we transfer your personal information to a jurisdiction outside of the EEA, we ensure it is afforded a similar degree of protection as that provided under the GDPR, by:

relying on an adequacy decision of the European Commission; or

implementing additional safeguards (such as the European Commission approved standard data protection clauses), to ensure your personal information and individual rights are protected.

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

What steps do we take to keep your information safe?

We take a number of steps to ensure the safety and security of your personal information.

We have implemented appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

The systems that store personal information are kept in a secure environment. All FCG employees are trained and kept up-to-date on our security and privacy practices.

We also limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

Whilst we take all necessary steps to safeguard your personal information, the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information that transferred from you or to you via the internet.

Retention of personal information

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

We may retain your personal information for a longer period, in the event of a complaint or if we reasonably believe there is a possibility of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider:

the amount, nature and sensitivity of the personal information;

the potential risk of harm from unauthorised use or disclosure of your personal information;

the purposes for which we process your personal information and whether we can achieve those purposes through other means; and

the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact Data, Identity Data, Financial Data and Transaction Data) for five years after they cease being customers, for compliance with anti-money laundering legislation.

In some circumstances you can ask us to delete your personal information (see ‘Your individual rights’ below).

If we need to use information for research or statistical purposes, we will anonymise any personal information, so that you are not identifiable from the information and it can no longer be associated with you.

Your individual rights

We want to ensure you have control of the personal information you choose to share with us. Subject to certain exemptions and depending on the applicable laws (including in some cases, upon our legal bases for processing your personal information), there are a number of rights you have in relation to your personal information. A summary of your individual rights and how you can exercise them is set out below:

You have the right to be informed of how we collect and handle your personal information, as we seek to do in this Privacy Notice.

You have the right to request access to the personal information that we hold about you.

You have the right to request we correct personal information we hold about you, if you think it is inaccurate, or incomplete.

You may have the right to receive a copy of personal information we hold about you (or request that we transfer this to another data controller) in a structured, commonly used, machine-readable format in certain circumstances (where we are processing this information on the basis of your consent, or where the processing is conducted on the basis of a contract);

In certain circumstances, you may have the right to ask us to limit or cease our processing of we hold about you.

You have the right to ask us not to process your information for marketing purposes (see “Opting out” above). Please note that we may still need to send you communications relating to transactions or your use of the Services.

You may have the right to object to our processing of your personal information when such processing is based on our legitimate interests (see “Our legitimate interests” above). Before using your personal information for our legitimate interests, we balance these interests against your rights and freedoms; however, if you consider that you have grounds to object to this, you can explain this to us, and we will review your request.

You may have the right to obtain an explanation of, and object to, any automated decision-making, which produces a legal effect or similarly significant effects. We do use your information to personalise our Site and the Services to make sure they are relevant to you; however we do not engage in automated processing with legal or similarly significant effects.

In cases where we process your personal information based on your consent, you can withdraw your consent at any time by contacting us. This does not affect the legality of any processing carried out before you withdrew your consent.

If you have unresolved concerns, you also have the right to complain about us to the relevant data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Please note that, notwithstanding the rights listed above, we reserve the right to retain certain information for our record-keeping purposes, and to defend ourselves against any legal claims.

How to exercise your individual rights

Updating and correcting your personal information – BAXE App Users

If you are a BAXE app user, it is important that the personal data we hold about you is accurate and current.You can easily update or correct certain personal information via the Account settings available in the app. To change or update your information, follow the steps set out below:

  1. Tap on the “Account” button on your Launchpad.
  2. From there, select the “Profile” button from the Account menu
  3. This will open a list of all your profile options
  4. Change your profile by editing the text boxes
  5. Once you are done tap “Confirm”.

You can make a request to exercise any of your other individual rights at any time, by contacting us using the contact details set out below.

We try to respond to all legitimate requests within 30 days of receipt. Occasionally, it may take us longer than 30 days to respond, if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and we will keep you updated. If there is a delay or dispute as to whether we have the right to continue using your personal information, we will restrict any further use of your information until the request is honoured or the dispute is resolved.

We may need to request some additional information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure we take to ensure that we are disclosing personal information to the right person. We may also contact you to ask you for further information in relation to your request, to help us process your request and to speed up our response.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep. You will never be discriminated against for having exercised your individual rights.

If you have a concern about how we handle your personal information, you can contact our Data Protection Officer to make a complaint. We ask that you first make this complaint to us in writing, so that we can do our best to address it for you.

If you are unhappy with our response or if you have unresolved concerns, you may also have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

If you reside in Australian, you can make a complaint to the Office of the Information Commissioner.

If you wish to make a compliant to a data protection authority in the EEA, you can find the contact details of the appropriate authority the official website of the European Data Protection Board.

How to contact us

If you have any questions about the information in this Privacy Notice or how we handle your personal information, if you need to access this Privacy Notice in a different format, or if you would like to exercise your individual rights, you can contact our Data Protection Officer at any time, using the contact details below:

Email: [email protected]
Telephone: 300 51 3302
Address: FCG Financial Services Pty Ltd
Level 25, Waterfront Place
1 Eagle Street Brisbane QLD
Brisbane QLD 4000 Australia
Attention: Data Protection Officer

Changes to this policy

We keep our Privacy Policy under regular review. If we decide to change our Privacy Notice, we will post those changes on our Sites, you are always aware of what information we collect, how we use it, and the steps we take to protect it.

If you have questions or concerns regarding this Notice, please contact our Data Protection Officer using the contact details above.

December 2022