PRIVACY POLICY

The current policy is in effect as of October 9, 2023 in the editorial office.

This privacy policy describes how Bitcos carries out any action (operation) or a series of actions (operations), performed with or without the use of automated means, with personal data, including: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data from its websites:

• https://bitcos.ru • https://bitcos.org • https://blog.bitcos.org

The Real Politics applies to the websites, Bitcos Platform, applications, products, and services (hereinafter referred to as "Bitcos Platform", "Services"), on which it is posted, connected or mentioned. 

By using the Bitcos platform, you accept the terms of this Policy and the terms of service:

• Consent for collection;

• Consent for processing;

• Consent for Disclosure and Storage of Your Information.

If you haven't done so already, please take a moment to familiarize yourself with our terms of use. 

The terms of use contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis, rather than as part of any class action, claim, lawsuit, etc. 

IF YOU DISAGREE WITH ANY PART OF OUR PRIVACY POLICY OR TERMS OF USE, PLEASE DO NOT USE THE Bitcos PLATFORM AND/OR SERVICES.

Bitcos periodically updates this Policy and has the right to unilaterally change its terms at any time.
We recommend that you regularly check the content of this Policy for possible changes. Unless otherwise provided by the Policy, all changes made to it will take effect after we publish the new terms and/or after making changes to this Policy. In all cases, your continued use of the Bitcos Platform and Services after the publication of any changes to this Policy means your acceptance of such changes.

Bitcos guided by the provisions of the current legislation of the Russian Federation.

Bitcos performs the processing of personal data of the requirements provided for by Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" and this Policy.

I. Purposes of personal data processing

1.1. Ensuring the protection of human and civil rights and freedoms in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets;

1.2. promotion of Bitcos products on the market by making direct contacts with potential consumers via communication and the Internet, providing them with software developed by Bitcos for use, concluding contracts with an unlimited number of persons, including through smart contracts;

1.3. to ensure compliance with current legislation (including countering the legalization (laundering) of proceeds from crime, financing of terrorism and financing the proliferation of weapons of mass destruction, AML and KYC procedures, requests from government agencies or other similar legal procedures;

1.4. to protect, investigate and prevent fraudulent, unauthorized or illegal activities.

1.5. Principles of personal data collection and processing
When collecting and processing personal data, Bitcos adheres to the following principles:

• legality and justice;

• restrictions on the processing of personal data to achieve specific, predetermined and legitimate goals;

• preventing the processing of personal data incompatible with the purposes of personal data collection;

• preventing the consolidation of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;

• compliance of the content and volume of the processed personal data with the stated purposes of processing;

• preventing redundancy of the processed personal data in relation to the stated purposes of processing;

• ensuring the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of personal data processing, as well as taking measures to delete or clarify incomplete or inaccurate data;

• transparency of personal data processing: the subject of personal data may be provided with relevant information regarding the processing of his personal data;

• the storage of personal data in a form that allows you to identify the subject of personal data, no longer than the stated purposes of personal data processing require.

II. Information that is collected Bitcos

We we get иinformation about you in various ways, it may include:

• Identification information such as your first name, last name, username or similar identifier, date of birth and gender;

• Contact information such as your mailing address, email address and phone number;

• Profile information such as your username and password, interests, preferences, reviews and survey responses;
• Feedback and correspondence, for example, information that you provide in your survey responses when you participate in market research, report problems with the Service, receive customer support or otherwise correspond with us;

• Financial information such as your credit card or other payment card details, bank account number, financial assets; 

• Transaction information, such as information about purchases that you make through the Bitcos Platform and payment details;
• Usage information, for example, information about how you use the Bitcos Platform, Services and interact with us;

• Marketing information, such as your preferences for receiving marketing messages and information about how you interact with them;

• Technical information, network information about transactions.

We do not collect or record seed phrases, private keys and blockchain addresses.

Log data - the Internet Protocol (IP) address of the user, the type of device and browser, the operating system, the pages or functions of our Sites that the user viewed, as well as the time spent on these pages or functions, as well as the frequency with which the sites are used by the user, search terms, links to our sites, by which the user clicked or used, as well as other statistics. We use this information to administer the service and analyze (and may involve third parties in the analysis) this information to improve and improve the service by expanding its functions, capabilities, adapting to the needs and preferences of our users.
Cookies, local storage or similar technologies for trend analysis, site administration, tracking user movements on sites and collecting demographic information about our user base as a whole. Users can control the use of cookies and local storage at the level of a separate browser. 

We can also use Yandex. Metrica, Google Analytics, to offer you an optimized user interface. Please note that Bitcos does not use Yandex. Metrica, Google Analytics in your wallet.
You can configure your browser so that it refuses all or some of the browser cookies or warns you when websites set cookies or access them. 
If you disable or refuse cookies, please note that some parts of the Sites may become unavailable or work incorrectly.
Data is collected only on websites: bitcos.org , blog.bitcos.org.

IMPORTANT!

Information we will never collect - Bitcos will never ask you to share your private keys or wallet code.  Never trust anyone and websites that ask you to enter your private keys or Wallet recovery Phrase.

III. Procedure for processing personal data

Legal basis of personal data processing	Period of processing and storage of personal data
With the consent of the personal data subject to the processing of his/her personal data	During the period for which consent to the processing of personal data was given
To achieve the objectives stipulated by an international treaty of the Russian Federation or by law, to implement and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation	Within the period established by relevant international treaties or laws
When it is necessary to process personal data subject to publication or mandatory disclosure in accordance with the federal law	Within the period established by the relevant laws
To execute a judicial act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings	Within the period of time necessary for the execution of the relevant act
In connection with participation of a person in constitutional, civil, administrative, criminal proceedings, proceedings in arbitration courts	During the period of participation in the relevant legal proceedings, including the period of appeal (contestation) of judicial acts, except for cases when a longer period of personal data processing is established by the current legislation of the Russian Federation
To execute a contract to which the personal data subject is a party or a beneficiary or guarantor, as well as to conclude a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor	During the validity period of such agreement, unless a longer period of personal data processing is stipulated by the current legislation of the Russian Federation
To protect the life, health or other vital interests of the personal data subject, if it is impossible to obtain the consent of the personal data subject	Until the moment when obtaining the consent of the personal data subject becomes possible or when the relevant grounds threatening life, health or other vital interests cease to exist (whichever comes first)
To exercise the rights and legitimate interests of the operator or third parties, provided that the rights and freedoms of the subject of personal data are not violated	During the period necessary to exercise the rights and ensure the legitimate interests of the The specific term is determined by Bitcos taking into account the provisions of this Policy, internal documents and local regulations of Bitcos, as well as the principles of personal data processing and the requirements of the current legislation of the Russian Federation, including the termination of personal data processing when specific, predetermined and legitimate purposes of such processing are achieved

3.2. The data referred to in section III are processed Bitcos:
- with the use of automation;
- without the use of automation.

3.3. When processing personal data Bitcos applies legal, organizational and technical measures to ensure the security of personal data in accordance with Article 19 of the Federal Law of 27.07.2006 № 152-FZ "On Personal Data".

3.4. Conditions of personal data processing Bitcos:

1) personal data processing is carried out with the consent of the personal data subject to the processing of his/her personal data;

2) processing of personal data is necessary to achieve the purposes stipulated by the international treaty of the Russian Federation or by law, to perform and fulfill the functions, powers and duties assigned to Bitcos by the legislation of the Russian Federation;

3) processing of personal data is necessary for the execution of an agreement to which the personal data subject is a party or beneficiary, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

4) processing of personal data is necessary for the protection of life, health or other vital interests of the personal data subject, if it is impossible to obtain the consent of the personal data subject;

3.5. Bitcos on the basis of a contract may entrust the processing of personal data to a third party. The essential condition of such agreement is the right of this person to process personal data, the obligation to comply with the principles and rules of personal data processing stipulated by the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data", to maintain confidentiality of personal data, to take the necessary measures aimed at ensuring the fulfillment of obligations stipulated by this Federal Law.

3.6. Unless otherwise provided for by the legislation of the Russian Federation, Bitcos will cease processing personal data (in relation to any of the purposes stated above) and destroy it in the cases of: Bitcos liquidation; Bitcos reorganization resulting in termination of its operations; no longer have legal grounds for personal data processing and/or achieve the purposes of personal data processing.

3.7. The specific procedure for destroying personal data on media containing personal data, including external/removable electronic media, paper media and in personal data information systems, is determined by Bitcos in its internal documents and local regulations.

3.8. Bitcos when processing personal data: takes measures necessary and sufficient to ensure compliance with the requirements of the legislation of the Russian Federation, internal documents and local regulations of Bitcos in the field of personal data; takes legal, organizational and technical measures to protect personal data from illegal or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data; appoints a person responsible for the organization of personal data processing; issues internal documents defining Bitcos policy in relation to personal data processing, local acts on personal data processing, as well as local acts establishing procedures aimed at prevention and detection of violations of the legislation of the Russian Federation, elimination of consequences of such violations; familiarizing employees with documents in the field of personal data, including requirements to personal data protection, and training these employees; performs internal control and (or) audit of compliance of personal data processing with the requirements of the legislation of the Russian Federation and regulations adopted in accordance with it, other requirements to personal data protection, this Policy, internal documents and local regulations of Bitcos in the field of personal data; publishes or otherwise provides unrestricted access to this Policy; stops processing of personal data and destroys it in cases stipulated by the legislation of the Russian Federation; performs other actions provided for by the legislation of the Russian Federation in the field of personal data.

IV. Rights of the personal data subject

4.1. The person whose personal data is processed by Bitcos has the right to: to withdraw his/her earlier consent to the processing of personal data*; to receive information regarding the processing of personal data; to demand clarification of his/her personal data, their blocking or destruction, if personal data are incomplete, outdated, inaccurate, illegally obtained, not necessary for the stated purpose of processing, as well as to demand termination of personal data processing, if the purpose of such processing is achieved by Bitcos. To exercise other rights within the framework of the current legislation. * According to part 2 of article 9, parts 4 and 5 of article 21 of the Federal Law "On Personal Data" Bitcos has the right to continue processing personal data in the presence of other legal grounds.

4.2. If another procedure of interaction between Bitcos and the subject of personal data is not provided by the relevant document between them (for example, the contract or the text of consent to the processing of personal data), in order to realize the specified rights, the subject of personal data should send Bitcos a statement: in the form of an electronic document and signed with an electronic signature to e-mail support@bitcos.ru

4.3. Such application shall obligatorily contain a description of the personal data subject's requirements, as well as the following information:

• Full name of the subject of personal data;

• number of the main identity document of the personal data subject or his/her representative, information about the date of issue of the said document and the issuing authority OR other data allowing to unambiguously identify the personal data subject;

• Information confirming the individual's involvement with Bitcos, OR information otherwise confirming the processing of personal data by Bitcos;

• The signature of the personal data subject or their representative.

4.4. The personal data subject also has the right to challenge Bitcos' actions (or lack thereof) and decisions that violate their rights in the processing of personal data. This can be done by submitting a complaint to the authorized body for the protection of personal data subjects' rights (Roskomnadzor) or by filing a lawsuit in accordance with the legislation of the Russian Federation.

4.5. To ensure safe operation and protection of personal data, the User should follow the following recommendations:

• To use exclusively licensed software at the workplace;

• To monitor the security of access means, install all necessary security updates recommended by the software manufacturer;

• To install and regularly update licensed antivirus software, and regularly perform virus scans.;

• Not to download programs and data from unverified sources, and not to visit websites with questionable content;

• Not to log in to your personal account from random computers;

• Not to share with anyone the authentication data for accessing the Bitcos Platform, private keys, or any other data associated with accessing the Bitcos Platform.

V. Information on the implemented measures for the protection of personal data

5.1. When processing personal data, Bitcos takes necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as other unlawful actions with respect to personal data. Bitcos regularly reviews and updates these measures to ensure the best possible security of processed personal data - such measures are described in this Policy, internal documents and local regulatory acts of Bitcos.

5.2. These measures include:

• Development of threat models;

• Definition of threats to the security of personal data during their processing in personal data information systems;

• Application of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems, necessary to meet the requirements for personal data protection, compliance with which ensures the established levels of personal data security set by the Government of the Russian Federation.";

• Application of information protection means that have passed the established conformity assessment procedures.";

• Assessment of the effectiveness of security measures for personal data before the introduction of the personal data information system into operation;

• Detection of unauthorized access to personal data and taking measures;

• Recovery of personal data that has been modified or destroyed as a result of unauthorized access to them;

• Establishment of access rules for personal data processed in the personal data information system, as well as ensuring registration and accounting of all actions taken with personal data in the personal data information system;

• Control over the measures taken to ensure the security of personal data and the level of protection of personal data information systems;

• Accounting for machine carriers of personal data;

• Placement of technical means for processing personal data;

• Maintaining security equipment, alarm systems in constant readiness;

• Monitoring user actions, investigating cases of violation of personal data security requirements.

VI. NOTIFICATION for citizens of the European Union

6.1. Personal information With respect to EU data subjects, the "personal information" used in this Privacy Policy is equivalent to "personal data" as defined in the EU General Data Protection Regulation (GDPR). 

6.2. Confidential data
Some of the information you provide to us may constitute confidential data as defined in the GDPR (also called special categories of personal data), including identification of your race or ethnicity in government-issued identity documents.

6.3. Legal basis of processing: We use your personal information only in accordance with the law. We are obliged to inform you about the legal grounds for processing your personal information, which are described in the table below. If you have any questions about the legal grounds under which we process your personal information, please contact us at: support@bitcos.ru

6.4

Purpose of processing	Legal basis
To provide our service	The processing of your personal information is necessary to fulfill the contract governing the provision of Services, or to take the measures that you request before subscribing to the Service.
To communicate with you	Such data processing represents our legitimate interests. Before processing your personal information in our legitimate interests, we must take into account and balance any potential impact on you (both positive and negative) and your rights. We do not use your personal information for actions in which our interests outweigh any adverse impact on you (unless we have your consent or otherwise required or permitted by law).
Optimize our platform	We use your personal information to comply with applicable laws and our legal obligations, including anti-money laundering (AML) laws and "know your customer" (KYC) requirements.
For compliance, fraud prevention and security	If our use of your personal information is based on your consent, you have the right to withdraw it at any time by the method specified in the Service, or by contacting us at support@bitcos.ru specify email

6.5. We may use your personal information for reasons not described in this Privacy Policy, if we are allowed to do so by law and if the reason is compatible with the purpose for which we collected it. If we need to use your personal information for unrelated purposes, we will notify you and explain the applicable legal basis for such use. If we have relied on your consent for specific use of your personal information, we will request your consent for any unrelated purposes.

6.6. Your rights

According to GDPR, you have certain rights with respect to your personal information. You may ask us to take the following actions regarding your personal information that we store: Refuse to send marketing messages that you previously agreed to receive. We may continue to send you messages related to the Bitcos Platform and other non-marketing messages. Provide you with information about how we process your personal information and provide you with access to your personal information. Update or correct inaccuracies in your personal information. Delete your personal information. Transfer a machine-readable copy of your personal information to you or to a third party of your choice. Restrict the processing of your personal information. Object to us relying on our legitimate interests as the basis for processing your personal information that affects your rights.
6.7. You can send these requests by email to support@bitcos.ru We may request specific information from you that will help us verify your identity and process your request.. 

6.8. Applicable law may require or allow us to reject your request. If we reject your request, we will tell you the reason, subject to legal restrictions. 

6.9. If you would like to file a complaint about our use of your personal information or respond to your requests regarding your personal information, you can contact us at support@bitcos.ru or file a complaint with the data protection regulator in your jurisdiction. 

6.10. Cross-border data transfer Please note that your personal data will be transferred, processed and stored in the Russian Federation. The laws on personal data protection in the Russian Federation may differ from the laws in your country of residence. You consent to the transfer of your information, including personal information, to the Russian Federation, as specified in this Privacy Policy, by visiting our Sites or using our service. Whenever we transfer your personal information from the EU to the Russian Federation or countries that, in the opinion of the European Commission, do not provide an adequate level of protection of personal information, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection. for personal information. Please contact us if you need more information about the specific mechanism we use when transferring your personal information outside the EU.

VII. Feedback

7.1. Bitcos welcomes feedback, comments, ideas and suggestions to improve this Policy, the Bitcos Platform, the Bitcos website, etc.

7.2. The User can send his suggestions to the email address denis@bitcos.ru By submitting their proposals, the User grants Bitcos a non-exclusive, worldwide, perpetual, irrevocable, fully paid, free, sublicensable and transferable license for all intellectual property rights. Bitcos has the right to use them, copy them, modify them at its discretion, delete them, transfer them to third parties and perform other actions.

VIII. Final provisions

If any provision of this Policy or part thereof becomes invalid or unenforceable to some extent, this does not affect the validity and applicability of other provisions of this Policy.