September 21, 2020

BitCuco

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Privacy Policy

Last Update September, 28th of 2019.

The following privacy policy in terms of the general statutes referred to in the 58th article of the mexican law to regulate the Financial Technology Institutions (ITF) as well as the Federal Law on Protection of Personal Data Held by Individuals (the “LFPDPPP”) and its Regulations (hereinafter jointly the law) applies to both sites www.logicfen.org and bitcu.co as well to the applications and tools related to our services, without distinction as to the form, means or procedure used to obtain or use them, to be responsible for the use, management and confidentiality of personal data provided by its customers, collection, maintenance, use, storage and disclosure of information collected from users within the BITCUCO website (bitcu.co, as successive BITCUCO) and any related services provided by Logicfen SAPI of C.V. (hereinafter Logicfen) and its associates.You, as the owner of the personal data, by deciding in an informed and free way to use our services, you express your consent regarding the scope of this Privacy Policy at the moment of registering, obtaining access, creating an account or using our services, contents, functions, programs, functionalities and technology that make up our website, application programs and related tools (jointly in the services).This privacy notice is only valid in the Spanish language, being translated into other languages for ease of reading by the user.

DEFINITIONS.

For the purposes of the following Privacy Policy it is understood as:Associates: Any legal entity with which Logicfen has commercial agreements to facilitate the sending and receiving of transactions as well as those that contribute to the implementation of the Customer Knowledge Policy (KYC) and other measures to prevent operations with resources of illegal origin.Managers: Person or legal entity that alone or jointly with others treats personal data on behalf of the responsible person.Holder: The natural person to whom the personal data correspond.Transfer: Any communication of data made to a person other than the responsible or manager.Treatment: The collection, use, disclosure or storage of personal data by any form. The use covers any action of access, handling, use, transfer or disposition of personal data.Responsible: Company or person who decides on the processing of personal data.User: Anyone who accesses and makes use of the BITCUCO platform and as well as the sites, applications and tools related to our services.

IDENTITY AND ADDRESS OF THE RESPONSIBLE

This Privacy Policy establishes the terms and conditions under which Logicfen, with address to hear and receive notifications in Ozumba, State of Mexico in its capacity as responsible, will treat the personal data of the holder.Contact informationEmail: support@bitcu.co
YOUR PERSONAL INFORMATION IN OUR POSSESSION WE COLLECT:
• Identification data, such as name, last name, age, nationality, date of birth, number, identity number or voter code, RFC, CURP or other similar information.
• Contact information, such as address, telephone, email and other similar information.
• Habits and events of browsing, IP address and data of cookies, geolocation and device information.
• Financial data, such as bank account numbers and/or credit or debit card numbers, tax data, employment information, patrimonial information and funds.
• Photography and digital signature.
• Proof of address (receipt of payment for home services such as, among others, supply of electricity, telephony, natural gas, property tax, supply, cable, water or bank statements).
• CLABE account number and payer bank, if applicable.
• Bitcoin’s personal use address and other cryptocurrencies addresses, if applicable.
• Other data that may be required in the general dispositions applicable to the Logicfen activity as well as data referring to the access and/or use derived from the habitual development of the use of the Logicfen services.
• Logicfen session time.
• Language preferences.
• Links that visit / where the traffic comes from.

DATA IN SOCIAL NETWORKS

When registering in our social networks, it will be understood that the user’s data (Personal Data Owner) is correct and the username is the responsibility of the User. In this sense, Logicfen is not responsible for any personality impersonation in any of the social networks that are handled.Social networks (such as Facebook®, Twitter®, WhatsApp® and LinkedIn® among others) are platforms for communication and interconnection between different users, are foreign to BITCUCO and Logicfen, therefore, they are not under the responsibility of Logicfen. However, dynamic and immediate communication with our customers and users, these or other communication platforms may be used to comply with the purposes of this Privacy Policy.The security of the user profile is the responsibility of the owner of the social network account, likewise, every user when registering in a Social Network obligatorily accepts their Declarations of Rights and Responsibilities (DDR) for example if they are a Facebook® user it is because expressly accepted, and therefore from the beginning of the relationship, all aspects related to privacy, protection of personal data, intellectual property of the contents and other aspects are regulated by these clauses, turning them into personal data located in public access sources.

PURPOSES OF DATA COLLECTION

Logicfen treats the holder’s personal data necessary to carry out the activities and managements focused on the fulfillment of the obligations originated and derived from any legal and commercial relationship established by reason of the provision of its services; administration of applications, the website, contact and customer service.Logicfen requires the collection and use of personal information for the following purposes:• To verify and confirm your identity and patrimonial situation.• To manage and operate the services and products you request or contract with us.• To avoid frauds in our system.• To provide and improve customer service.• To comply with the rules of Prevention of Operations with resources of Illicit Origin.• To send emails.• To get in touch with users by any means we consider necessary.• To process payments, including deposits and withdrawals.• To comply with any local or federal law.• To carry out the regular commercial activities of Logicfen.Likewise, Logicfen treats the personal data of the holders to additional purposes, such as sending notifications, notices, promotional messages or communications for marketing or advertising or telemarketing purposes on new or existing products and services, whether their own or from commercial partners; conduct surveys; statistics; market studies, records on consumer habits through automatic data capture tools, interests and behavior.

DATA TRANSFERS

In accordance with articles 17, 68, 74 of the Regulations of the Federal Law on the Protection of Personal Data Held by Individuals, your personal data may be transferred and processed inside and outside the country by persons other than Logicfen. In this sense, your information may be shared with the Logicfen associates in order to comply with their legal and / or commercial obligations, for which they have entered into or entered into various agreements both in Mexico and abroad.The recipients of personal data are obliged by virtue of the corresponding contract, to maintain the confidentiality of the personal data provided and to observe this Privacy Policy.Their information may be shared with any division of Logicfen or its subsidiaries for the same purposes set forth in this notice as well as to provide the best possible user experience.Their personal information may be forwarded, stored and processed in a country other than where it was provided, which will be carried out in accordance with applicable data protection laws.We take measures to protect personal information regardless of the country where it is stored or referred to.In some cases, we share their financial or patrimonial assets based on sections I, III, IV, V and VII of article 37 of the LFPDPPP. Similarly, Logicfen may not require the consent of the individual for the transmission of their information in all cases of Article 10 of the aforementioned law. Logicfen may collect personal data of the Holder by any means of contact, digital or physical, between the Holder and the Responsible. It can also collect personal data indirectly through public access sources and from any other available sources.Logicfen and/or its associates collect personal identification data, financial and/or patrimonial, working and contact data, as well as collect personal data related to physical characteristics and biometric data. Personal data that we collect through emails, telefax, filling of formats, telephone calls, audio recordings, images or videos, audiovisual or VoIP communications: any processing of your personal data will be subject to their consent, which may be manifested to the corresponding department of Logicfen that you have contacted. Logicfen is likely to record the content of the call for quality purposes as well as documentary evidence.Through other sources, we may obtain information from you, from other sources permitted by law. The data that we obtain by these means can be, among others: Government Sources of public character, Lists of International Organizations of a public nature, Information on social networks and Photos via Google Maps.

CONSENT OF THE HOLDER

For purposes of the provisions of the Federal Law on Protection of Personal Data Held by Private Parties (the “LFPDPPP”) and other applicable legislation, the Owner states:• That this Privacy Policy has been made known to the Responsible.• Have read, understood and agreed to the terms set forth.• That you give your consent regarding the processing of your personal data.• That gives consent for BITCUCO, Logicfen and its associates to make transfers and/or referrals of personal data in terms of this Privacy Policy.

BY CREATING AN ACCOUNT

This procedure is not automatic, but is carried out only when the user decides to open an account in BitCuco. The user is the one who provides the data and can decide, among different options, with which documents proves his identity. Logicfen understands that, in the event that the user decides to use a bank account statement as proof of address, in accordance with the provisions of Article 8 of the Federal Law on Protection of Personal Data Held by Individuals, the fact that the user uploads his bank account statement by his own will, to our platform is considered as the express consent for the use or treatment of his personal financial or patrimonial data.The personal data that we collect through emails, fax, filling of formats, telephone calls, audio recordings, images or videos, audiovisual or VoIP communications: any processing of your personal data will be subject to your consent, which may manifest to the corresponding Logicfen department that you have contacted. Logicfen is likely to record the content of the call for quality purposes as well as documentary evidence. You can oppose the processing of your data for secondary purposes through the means at your disposal for the exercise of your ARCO rights, according to the procedure indicated below.

USE OF COOKIES

Cookies are text files that are downloaded automatically and stored on the hard disk of the user’s computer when browsing a specific Internet page, which allows the Internet server to remember some information about this user, including your preferences for viewing the pages on that server, name and password.In most browsers cookies are automatically accepted by virtue of their default settings, you can adjust your browser preferences to accept or reject cookies. The deactivation of cookies can disable various functions of Logicfen site, BITCUCO site or may cause them not to display correctly.We inform you that Logicfen and its products use cookies to obtain information from Users, such as the following:• Their browser type and operating system.• The Internet pages they visit.• The links that follow.• The IP address.• The site they visited before entering ours.
PROCEDURE TO REQUEST ARCO RIGHTS AND REVOCATION OF CONSENT
The Owner has, at all times, the right to know what personal data we have about you, what we use them for and the conditions of use we give them (Access). Likewise, it is your right to request the correction of your personal information in case it is inaccurate or incomplete (Rectification); that we remove it from our records or databases when it considers that it is not being used in accordance with the principles, duties and obligations set forth in the regulations (Cancellation); as well as oppose the use of your personal data for specific purposes (Opposition). These rights are known as ARCO rights.To request any of the ARCO rights, you must send an email to support@bitcu.co, which must contain the following information and documentation:• Name of the Owner and address or other means to communicate the response to your request.• A valid documents that prove your identity (simple copy in printed or electronic format of your voter card or passport) or, where appropriate, the legal representation of the Holder (simple copy in printed or electronic form of the simple power of attorney with signature autograph of the Holder with blue ink, of the agent and their corresponding valid official identifications – voter’s credential or passport).• The clear and precise description of the data with respect to which it seeks to request any of the ARCO rights, and any other element or document that facilitates the location of the Holder’s personal data.• In the case of requests for rectification of personal data, the Holder must also indicate the modifications to be made and provide the documentation supporting their request.In order to comply with the obligation of access to their personal data, prior accreditation of the identity of the owner or personality of the representative will be made; making the information available on site at the address of the Responsible. Another means may be agreed between the Holder and the Responsible Party, provided that the requested information so permits.The contact details of the person or department that will process applications for the request of ARCO rights, as well as address any questions you may have regarding the processing of your information is the following:

Email: support@bitcu.co