Last updated November, 2021
3. What Information is collected
3.1 What is personal data?
3.2 How and what data is collected when using the WebApp
When the WebApp is used to access the platform, an account or profile, fill in forms provided on the WebApp, subscribe to our services, notifications or newsletters, or report a problem with the WebApp, 4bridges GmbH may collect, store and use certain personal information that is disclosed. The information collected may include (but is not limited to): IP address, IBAN, email address, telephone number, feedback and log-in information. 4bridges GmbH may also collect information during visit and interaction with the WebApp through the use of technologies such as cookies. The following are examples of information 4bridges GmbH may collect:
• information about device, browser or operating system;
• time zone setting;
• IP address;
• information about interactions with the WebApp (such as scrolling and clicks);
• information about the use and actions taken within the WebApp;
• length of time on the WebApp and time spent within certain sections;
• response times; and
• download errors.
Users can refer to the device’s help material to learn what controls to be used to remove cookies, block cookies, or disable IDFA tracking. If Users do so, it may affect the user experience of a Website
4bridges GmbH may also partner with third parties who may collect anonymous usage or statistical data through the use of the App (including, for example, sub-contractors in technical, payment and/or delivery services, business partners, advertising networks, analytics providers).
), Google or Apple directly if you have any questions regarding the use of this technology.
3.3 Updating User Information
If Users like to update information, they have previously shared with 4bridges GmbH, please contact 4bridges GmbH via Email at [email protected]
4. Processing of User Information
4.1 Lawful basis for processing User information
4bridges GmbH will only use personal data when the law allows us to. Most commonly 4bridges GmbH will use personal data in the following circumstances:
• Where Users have asked to do so, or consented to doing so;
• Where 4bridges GmbH needs to do so in order to perform a contract entered into with the User;
• Where it is necessary for a legitimate interest (or those of a third party) and the fundamental rights do not override those interests; and
• Where 4bridges GmbH need to comply with a legal or regulatory obligation.
Users will receive marketing messages if they have given consent to do so or if they have provided feedback on our WebApp and have not opted out of receiving marketing messages. To unsubscribe from marketing emails at any time, Users can click on the unsubscribe link at the bottom of any marketing email and update their account preferences. Users may also contact 4bridges GmbH at ([email protected]
) to unsubscribe from any marketing materials.
4.2 Sharing User Information
4bridges GmbH may share User Information in the following ways:
• with members of the group, i.e. subsidiaries or affiliated companies.
• with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract entered into with or operating on behalf of the user (see “Service Providers” below); or
• with analytics that assist in the improvement and optimisation of the WebApp.
4bridges GmbH may also disclose personal information to third parties in the following events:
• if 4bridges GmbH intends to sell or buy any business or assets, in which case 4bridges GmbH might disclose personal information to the prospective seller or buyer of such business or assets;
• if 4bridges GmbH or substantially all of its assets are acquired by a third party, in which case personal information held by 4bridges GmbH will be one of the transferred assets; or
• if 4bridges GmbH is under a duty to disclose or share personal information in order to comply with any legal obligation, or to protect the rights, property, or safety of the company, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
4.3 Service Providers
Selected Service Providers provide a variety of administrative, statistical, and technical services. 4bridges GmbH will only provide Service Providers with the minimum amount of personal data they need to fulfil the services requested, and 4bridges GmbH stipulate that they protect this information and do not use it for any other purpose. 4bridges GmbH takes its relationships seriously and oblige its data processors to sign contracts that clearly set out their commitment to respecting individual rights, and their commitments to assisting 4bridges GmbH to help Users exercise their rights as a data subject.
4.5 Links to third party sites
4.4 Other Disclosures
During the use of the Website or WebApp, User’s App Store provider and mobile network operator may also collect personal information about the use of the App such as identity, usage and location.
5. Information life cycle
4bridges GmbH will hold personal information on its systems only for as long as required to provide the community with the requested products and services, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Personal data life cycle may be for a longer period in the event of a complaint or if reasonably believe there is a prospect of litigation in respect to the relationship. For user requests to delete or anonymise data: see ‘Rights’ below for further information. In some circumstances anonymised personal data may be used for research or statistical purposes without further notice.
4bridges GmbH takes the protection of information very seriously. Appropriate physical, electronic and managerial security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers, passwords and industry standard encryption for data both in transit and at rest have been put in place.
When the Website or WebApp request a password or PIN code that enables access to certain parts of the application, the user is responsible for keeping this password or PIN code confidential. 4bridges GmbH never will ask to share a password or PIN code with anyone.
To interact with the Website or WebApp the user needs an external wallet i.e., Trezor or ledger hardware wallet, to whitelist it inside the application. 4bridges GmbH does not have, at any point in time, access to the user’s private keys and funds on their external wallets. Users are responsible for keeping the private key confidential. 4bridges GmbH asks all Users not to share private keys with anyone . If Users lose or give away private keys, they lose or give away their crypto assets.
4bridges GmbH limit access to personal data to employees, agents, contractors and other third parties who have a business, need to know. They will only process personal data as instructed and they are subject to a duty of confidentiality. 4bridges GmbH has put in place procedures to deal with any suspected personal data breach and will notify users and any applicable regulator of a breach where 4bridges GmbH is legally required to do so.
7. International Data Transfers
Please note that some service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for 4bridges GmbH or for suppliers and may be engaged in, among other things, the fulfilment of the user’s request for information, products and services, the processing of user’s payment details and the provision of support services.
Where data is transferred to a service provider that is outside of the EEA 4bridges GmbH seeks to ensure that appropriate safeguards are in place to make sure that personal data is held securely and that personal rights as a data subject are upheld. Transfers of personal data are either made:
• to a country recognised by the European Commission as providing an adequate level of protection; or
• to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.
• By submitting personal information, Users agree to this transfer, storing or processing.
Users which like to receive more information about International Data Transfers please contact 4bridges GmbH at [email protected]
8. User Rights
As a data subject users have a number of rights in relation to their personal data. Below, 4bridges GmbH describes the various user rights as well as how to exercise them.
8.1 Right of Access
Users, at any time, request access to the personal data (this right being described as a “subject access request”). This right entitles the User to receive a copy of the personal data to check that it is correct and to ensure that 4bridges GmbH is processing that personal data lawfully. It is not a right that allows to request personal data about other users, or a right to request specific documents from 4bridges GmbH that do not relate to own personal data.
Users can exercise this right at any time by writing to 4bridges GmbH ([email protected]
) and inform 4bridges GmbH about making a “subject access request”. There is no need to fill in a specific form to make a “subject access request”
8.2 Right to Rectification and Erasure
Users may, at any time, request to correct personal data that is believed to be incorrect or inaccurate. 4bridges GmbHmay ask to verify any new data which is provided and may take own steps to check that the new data is right.
Users may also ask to erase personal data if not believed that 4bridges GmbH need to continue retaining it. This right is described as the “right to be forgotten”. Although 4bridges GmbH will do everything to respect your requests about personal data, it may not always be possible to erase all of your personal data as there may be legal requirements to keep certain personal data or technical limitations to the data 4bridges GmbH can delete.
There may also be legitimate interests in keeping certain data including, amongst others, if the data is required for the Website or WebApp to function. If this is the case, 4bridges GmbH will continue to process this data.
If erasure is not technically possible or 4bridges GmbH believes that there is a good legal reason to continue processing personal data, 4bridges GmbH will inform and name the reason at the time of responding to the request.
Users can exercise this right at any time by writing to 4bridges GmbH ([email protected]
) and informing 4bridges GmbH of making a request to have personal data rectified or erased and on what basis this request is made. If users like 4bridges GmbH to replace inaccurate data with new data, users shall inform 4bridges GmbH about that new data. No need to fill in a specific form to make this kind of request.
8.3 Right to Restrict Processing
Where personal data is processed on the basis of a legitimate interest, the user is entitled to ask 4bridges GmbH to stop processing the data in that way if the user feels that 4bridges GmbH continuing to do so impacts on the user’s fundamental rights and freedoms or if the user feels that those legitimate interests are not valid.
The user may also ask 4bridges GmbH to stop processing personal data (a) if the user disputes the accuracy of that personal data and want 4bridges GmbH to verify that data’s accuracy; (b) where it has been established that 4bridges GmbH use of the data is unlawful but the user does not want us to erase it; (c) where 4bridges GmbH no longer needs to process personal data (and would otherwise dispose of it) but the user wish to continue storing it in order to enable the user to establish, exercise or defend legal claims.
If for any reason 4bridges GmbH believes that there is a good legal reason to continue processing personal data that the user has asked to stop processing, 4bridges GmbH will inform the user about the reasons, either at the time of the first respond to the request or after 4bridges GmbH has had the opportunity to consider and investigate it.
This right can be exercised at any time by writing to 4bridges GmbH at ([email protected]
) and informing 4bridges GmbH of making a request to have 4bridges GmbH stopped processing the relevant aspect of personal data and describing which of the above conditions is believed to be relevant to the request. Users do not have to fill in a specific form to make this kind of request.
8.4 Right to Portability
Where users wish to transfer certain personal data that 4bridges GmbH holds, which is processed by automated means, to a third party, users may write to 4bridges GmbH and ask to provide it in a commonly used machine-readable format.
Due to the work of 4bridges GmbH and the systems that are in use, 4bridges GmbH does not envisage this right being particularly relevant to the majority of individuals with whom it interacts. However, if a user wish to transfer data from 4bridges GmbH to a third party 4bridges GmbH is willing to support such requests but may charge the user for this service.
8.5 Right to object to processing
Users may object to processing of personal data where 4bridges GmbH rely on legitimate interest for processing personal data. 4bridges GmbH will comply with user requests unless there is a compelling overriding legitimate interest for processing or the need to continue processing personal data to establish, exercise or defend a legal claim.
8.6 Right to stop receiving communications
To unsubscribe from communications at any time, users can click on the unsubscribe link at the bottom of any email and update. For more details on the right to ask 4bridges GmbH to stop sending various kinds of communications, please contact ([email protected]
8.7 Right to object to automated Decision Making and Profiling
Each user has the right to be informed about the existence of any automated decision making and profiling of personal data and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects the user.
8.8 Withdrawal of Consent
Where 4bridges GmbH is relying on consent to process personal data, users may withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before the user withdraw the consent. If the user withdraw the consent, 4bridges GmbH may not be able to provide certain products or services to the user. 4bridges GmbH will advise if this is the case at the time of withdraw the consent.
8.9 Exercising User Rights
When a user is making a request to exercise user rights, 4bridges GmbH is entitled to ask for a prove of the user. 4bridges GmbH may ask to provide copies of relevant ID documents to help to verify the identity.
It will help 4bridges GmbH to process user requests if users clearly state which right, they wish to exercise and, where relevant, why it is that the user is exercising it. The clearer and more specific users can be, the faster and more efficiently 4bridges GmbH can deal with the request. If users do not provide sufficient information, then 4bridges GmbH may delay actioning the request until the user has provided 4bridges GmbH with additional information.
9. Contact Details