PRIVACY POLICY | Digital Gold

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DIGITAL GOLD
Digital Gold Laboratory Co.,Ltd.
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PRIVACY POLICY
Digital Gold Privacy Policy
Scope and Consent
This policy mentions the ways Digital Gold Laboratory Co., Ltd. and its subsidiaries (hereinafter, “Digital Gold”, “we”, “our” or “us”) collect, store, use and protect Personal Data. The purpose of this policy is to ensure that Digital Gold complies with applicable for Hong Kong (hereinafter, HK) regulations, and the United States (hereinafter, “US”), European Union (hereinafter, “EU”) data protection laws such as the General Data Protection Regulation (hereinafter, “GDPR”). Digital Gold’s Services include merchant processing services, products, or any other features, technologies or functionalities (hereinafter: “Services”) offered by Digital Gold Laboratory Co., Ltd.

This policy mentions the ways Digital Gold Laboratory Co., Ltd. and its subsidiaries (hereinafter, “Digital Gold”, “we”, “our” or “us”) collect, store, use and protect Personal Data. The purpose of this policy is to ensure that Digital Gold complies with applicable for (hereinafter, HK), and United States (hereinafter, “US”) federal and regulations, and European Union (hereinafter, “EU”) data protection laws such as the General Data Protection Regulation (hereinafter, “GDPR”). Digital Gold’s Services include merchant processing services, products, or any other features, technologies or functionalities (hereinafter: “Services”) offered by Digital Gold Laboratory Co., Ltd. Users accept this Policy by visiting our website and/or by using our Services.

There are six types of data subjects whose personal data we may process:

Visitors of our websites (http://www.digitalgold-laboratory.com/, https://user.digitalgold-laboratory.com);
Merchants that sign up for our Services;
Shoppers who indirectly interface with Digital Gold when paying a merchant’s invoice that is forwarded by Digital Gold to merchants during checkout;
Shoppers who indirectly interface with Digital Gold when requesting a cryptocurrency withdrawal via a Merchant that is using Digital Gold’s Services.
What is “personally identifiable information?”
“Personally Identifiable Information” (hereinafter: “Personal Data”) is any information that can be directly associated with a specific person and can be used to identify that person. A prime example of identifiable information is a person’s name.

What kind of personal data do we collect?
The Personal Data we collect depends on the type of user:

Visitors: We may collect the following Personal Data for visitors of our websites (http://www.digitalgold-laboratory.com/, https://user.digitalgold-laboratory.com):
IP address
Email address (e.g. when sign in, 2FA, subscribe to our blog or opt in to receive other marketing materials)
Name (e.g. when you submit a support request)
We may collect information about a visitor’s computer or other access devices for fraud prevention purposes.

Merchants: When opening an account, we may collect the following types of Personal Data of the beneficial owner or any user that is added to the account:
Name
Email address
Date of birth
Identification documents (such as a passport or driver’s license)
We may use this Personal Data for risk-management purposes (i.e. to verify merchant’s identity or address). We may also obtain information about our merchants from third parties such as credit bureaus and identity verification services. We ensure that such third parties adhere to the same data protection principles as Digital Gold.

Shoppers of merchants: When a shopper is paying a Digital Gold invoice, the following Personal Data is captured:
Email address
IP addresses used to view the Digital Gold invoice
The email address is either automatically provided by the merchant or manually entered by the shopper. This enables our system to send an email to Shoppers directly to obtain a cryptocurrency refund address in case of a payment exception (e.g. overpayments, underpayments, etc.). This creates a more seamless payment experience for both the merchant and the shopper.


Wallet holders: For wallet holders, Digital Gold collects the following Personal Data:
Email address
The email address collection is optional in case the user would like to receive email notifications and (if selected) Digital Gold news and product updates and can be removed at any point in time.

Shoppers that use Digital Gold’s cryptocurrency withdrawal service: If user need to record the payment information, optionally user can select to preserve the following Personal Data in Digital Gold Smart Contract:
Name
Email address
Identification documents (such as a passport or a driver’s license)
Proof of address document (such as a bank statement or a utility bill)
Sensitive or special categories of personal data
Digital Gold does not process any sensitive personal information, such as religion, race, ethnicity and/or political views.
Why we collect personal information
Our primary purpose for collecting Personal Data is to provide you with a secure, smooth, efficient, and customized experience. We may use your Personal Data to:

comply with applicable laws and regulations;
provide the Digital Gold Services and customer support you request;
process transactions and send notices about your transactions;
resolve disputes, collect fees, and troubleshoot problems;
prevent potentially prohibited or illegal activities, and enforce our Terms of Use;
customize, measure, and improve the Digital Gold Services and the content and layout of our website and applications;
deliver targeted marketing, service update notices, and promotional offers based on your communication preferences;
compare information for accuracy and verify it with third parties.
How we protect and store personal information
We take security of data very seriously. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to Personal Data only for those employees who require it to fulfill their job responsibilities.

In addition to this Privacy Policy, we have several other (internal) policies and procedures in place that deal with data security:

IT Security Policy: This policy mentions how we store and process your Personal Data on our servers in the United States and elsewhere in the world where Digital Gold facilities are located. It also mentions how we protect it by maintaining physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations, and EU data protection laws.
Incident Response Policy: This policy mentions our response to an information security incident.
Data Breach Policy: This policy specifically mentions what steps will be taken by us in case of a data breach. This includes notifying the supervisory authorities and the affected data subjects when required.
Business Continuity and Disaster Recovery Policy: This policy mentions how we recover from a disaster and what steps will be taken to continue or resume routine business operations.
Cookie Policy: This policy mentions how Digital Gold uses cookies to customize the Digital Gold Services, content and advertising; measure promotional effectiveness, and promote trust and safety.
How we share personal data with third parties
We may share your Personal Data with:

Other Digital Gold entities, in order to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services and communications;
Service providers under contract who help with our business operations. We will make sure that these third parties have appropriate internal controls in place to protect any Personal Data that might be transferred;
Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Digital Gold; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary to report suspected illegal activity or to investigate violations of our Terms of Use.
In cases of suspected fraud or in connection with an ongoing investigation, we may share certain shopper information with our merchants.
Please note that these third parties may be in other countries where the laws on processing Personal Data may be less stringent than in your country. We deploy the following safeguards if we transfer Personal Data originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law:

Merchants can review and edit their information by logging in to their account and reviewing their Personal Data under the Settings tab on the Dashboard. If you wish to change information relating to your industry or company website, or if you wish delete your account, you can send a message from http://www.digitalgold-laboratory.com/contact.html. If you choose to delete your Digital Gold account, we will mark your account in our database as "Closed".
Marketing
We do not sell your Personal Data to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize the Digital Gold Services, content and advertising. If you do not wish to receive marketing communications from us or participate in our ad-customization programs, you can simply click the “unsubscribe” link at the bottom of the e-mail or you can send an message from http://www.digitalgold-laboratory.com/contact.html.
Contact
To communicate with our Data Protection Officer, please send message by http://www.digitalgold-laboratory.com/contact.html. Subject to applicable law, you also have the right to lodge a complaint with your local Data Protection Authority or the Privacy Commissioner for Personal Data, Hong Kong, which is Digital Gold’s lead supervisory authority in the Hong Kong.
How we use cookies
What are cookies?
A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to “remember” your actions or preferences over time. Most browsers support cookies, but you can set your browser to decline them and can delete them whenever you like.

What type of cookies do we use?
When you access our website, we, or companies we hire to track how our website is used, may place small data files called “cookies” on your computer. We and our service providers also use cookies to customize the Digital Gold Services, content and advertising; measure promotional effectiveness, and promote trust and safety.

We send a “session cookie” to your computer when you sign in to your account or otherwise use the Digital Gold Services. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we do not need to ask you for your password on each page. Once you sign out or close your browser, this cookie expires and no longer has any effect.

We also use longer-lasting cookies for other purposes such as to display your email address on our sign in page, so that you don't need to retype the email address each time you sign in to your account.

We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our website. We may also collect information about your computer or other access device to mitigate risk and for fraud prevention purposes.

You may encounter cookies from third parties when using the Digital Gold Services on websites that we do not control (for example, if you view a web page created by a third party or use an application developed by a third party, there may be a cookie placed by that web page or application.)

Managing your cookie settings
You can manage cookies through the settings of your Internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies or delete all cookies. Please note that, if you choose to delete Digital Gold cookies, your access to some functionalities and areas of our website may be degraded or restricted.

Changes to this policy
We may amend this policy at any time by posting a revised version on our website. The revised version will be effective at the time we post it. In addition, if the revised version includes any substantial changes to the manner in which your Personal Data will be processed, we will provide you with 30 days prior notice by posting notification of the change on the “Privacy Policy” area of our website.

If you have questions concerning this Privacy Policy, please feel free to send us an email by http://www.digitalgold-laboratory.com/contact.html.
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