Privacy Policy
Welcome to Deepwaters! Trading without Trade-Offs.
Privacy, security and transparency at the same time is one of our highest priorities. All our trading and custody rules are published on www.deepwaters.xyz (the “Site”) for everyone to see. You can know we treat you fairly because we’re completely transparent with how we treat your assets.
The same goes with our privacy rules. In this Privacy Policy we inform you as our Account holders, potential Account holders, our customers without accounts, representatives of our customers (mainly employees and members of statutory bodies) and visitors of our Site about the use of your Persona Data which will be collected and processed throughout conclusion and performing a contract on use of our Services.
This Privacy Policy explains to you what data is being used, how, for how long, and what your rights are.
Ready? Here it goes!
Note: All capitalised words in this document have their meaning as attributed to them in our Terms & Conditions. You’re supposed to read both the documents alongside.
Who processes your data?
Your Personal Data is processed by our company, thus being the controller:
Deepwaters EU s.r.o., with its registered seat at Rybná 716/24, Staré Město, 110 00 Praha 1, the Czech Republic, ID No.: 179 11 257, Registered in the Commercial Register held by the Municipal Court in Prague, Section: C, File No.: 378583.
Do you have any questions? Feel free to contact us any time at privacy@deepwaters.xyz.
What data and on what legal grounds are processed?
We only use ordinary (basic) personal data such as name, surname, date of birth, e-mail, telephone number, etc., that could be used to identify you (“Personal Data”) that are necessary for creating your account on our Site, using our Services and carry out our KYC process as applicable. We also may use data regarding usage of our Services for the purposes stated below.
We do not process special categories of Personal Data (e.g. health data, data on your political views, etc.).
We process your Personal Data for the following purposes:
- Conclusion and performance of contract on Services
By accepting our Terms you enter into contract on provision of the Services which are defined in detail in the Terms.
Thus, we process Personal Data for due performance of our contractual duties towards our customers and provision of our Services. Such purpose includes also necessary communication relating to provision of the Services, e.g. about software updates, potential necessary system downtime, your feedback to the Services used, bug fixes, handling your customer complaints, your queries on our social network’s accounts, changes in Privacy Policy or Terms, as well as for responding to your requests for assistance or support via e-mail or phone, communication about termination of the contract, etc.
Transactional data on the Site will also be used to provide you with information on your User Account and deliver other aspects of the Services to you.
Provision of the Personal Data is a requirement for conclusion and performance of our contract.
If you choose to use our Services in a form of non-custodial wallet, you do not need to create an account on the Site. Thus, you do not need to provide us with your Personal Data for this purpose.
- Compliance and fulfilment of our legal duties
Our company is obliged to perform legal duties imposed on us by the Applicable Law, e.g. duties relating to AML (and know-your-customer procedure), accounting and tax purposes, archiving and other legal duties to which we are subject.
Providing and processing of such personal data is therefore a legal requirement.
- Our legitimate interest on processing data
We also process the Personal Data in necessary extent based on the following legitimate interests of Deepwaters:
- To communicate with you via e-mail about special offers, benefits, discounts, and interesting marketing activities in a form of a newsletter or irregular e-mail announcements. You may opt out of such marketing e-mail communication at the moment of provision of your e-mail address to us upon creating your User Account and any time later by clicking the “unsubscribe” link found in each such e-mail or by contacting us via e-mail or telephone call announced to you during our business cooperation.
- To secure data and system security and avoid misuse of our Services. For this purpose, we may gather data tracked by our Site while using the Site or Services, such as frequency of use, engagement with particular features, common use patterns, etc., and devices data which may include information specific to your computer device (IP address, browser type, browser settings, browser configuration, language preferences).
- To improve our Site or Services. Your data on how you use our Site and Services in necessary extent (always in an anonymized or pseudonymised form, of course) is analysed and used to help us understand and improve the efficiency of certain features. Based on such improvements we can then better serve evolving needs of our users, including yourself or your company. The data is gathered by our Site.
- To protect our rights or interests or enforce our claims if such necessity comes out (e.g. when our financial claims are not satisfied, our Site was compromised or we need to enforce our right to damages, etc.).
You as a data subject have the right to object to the processing of your Personal Data based on our legitimate interest.
- Consent with sending marketing communications
If you are not our customer and you are interested in our Services and news, you may subscribe to our marketing communication we send via e-mail. If you do so, we’ll be processing your contact data necessary for delivering the marketing communications. You may withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
If you are Account Holder, the marketing communications will be sent to your e-mail address you provided when creating your account on the Site automatically based on our legitimate interest (for more information, please, see the section under letter c) above) unless you unsubscribe from such communication (more information under letter c) above).
- Consent with processing of data through cookies
When you visit our Site, we may process some of your data in necessary extent based on your consent with storing and using cookies for analytical, statistical or marketing purposes, however, only if you give us your consent to do so when entering our Site or any time later. Such data are primarily anonymous and help us understand how visitors of our Site interact with it.
Cookies are files with a small amount of data stored on your computer used as anonymous unique identifiers. We also use technical cookies strictly necessary for functioning of our Site without your consent. Detailed information on how we use cookies are described in our Cookies Policy below in this document.
How long do we process Personal Data?
We always process your data for a period necessary for the purpose of the processing:
- for conclusion and performance of the contract (provision of Services) we process data until the contract is terminated under the Terms
- for compliance with our legal duties for periods of time as stated in accordance with applicable law
- for purposes based on our legitimate interest. Your Personal Data is processed only for the duration of our legitimate interest which we continuously monitor and stop processing the data at the moment it is no longer necessary for the given purpose or when you successfully raise an objection against such processing. If you raise an objection or unsubscribe from e-mail marketing communication, the processing will be stopped immediately, and your data will be erased from our marketing communication database. In case of processing your data for protection or enforcement of our rights and interests, your data are processed for a limitation period stated by law within which we are entitled to protect or obliged to enforce our rights. For security reasons we process your data for several months until the capacity of the dedicated memory is full.
- for purpose of sending marketing communications based on your consent – until your consent is withdrawn or the processing is no longer necessary.
With whom do we share your data?
We may share your Personal Data with our partners which provide us with necessary services without which we cannot operate our company, provide our Services or fulfil our legal duties.
Our partners (e.g. accountants, tax advisors, software developers or support team) may process your personal data on our behalf as our data processors and only to the extent necessary to allow them to perform their services to us.
Our processors who provide us with various services are always chosen due to the quality of their security guarantees as well. Your Personal Data and data you entrust us with when using our Services or visiting our Site are in good hands. We always make sure of that.
Our Services may provide access to, integrate, or create user interfaces or interactions with Third Party Services. You acknowledge that it is impossible for us to monitor Third Party Services and that you access them at your own risk, subject to the terms and conditions and privacy policy of each Third-Party Services provider. Please, for more information refer to our Terms.
Apart from that, we may also provide necessary data to public authorities or third parties if we are bound to do so by applicable law or its necessary based on other reason (e.g. based on a third party legitimate interest to discover frauds, etc.).
Do we send your data outside the EU/EEA?
The answer is simple: No. We do not willingly send your Personal Data outside the EU/EEA.
All our servers where your Personal Data is stored, are located exclusively within the EU, and operated by our carefully chosen processors.
How do we make your data safe?
Privacy and security of all the data we process is our highest priority. Our Services and Site have been designed from scratch with security and privacy of all the data in mind. Thus, we always make sure to employ up-to-date technical, administrative and security measures above the standard market level.
What are your rights regarding your data?
In connection to the processing of your Personal Data, you have the right:
- to have access to and a copy of your Personal Data
- to request rectification of any inaccurate Personal Data
- to obtain restriction of processing the Personal Data in cases stated by the GDPR
- to have your Personal Data erased if certain conditions under the GDPR are met
- to receive the Personal Data in a structured, commonly used, and machine-readable format and to transmit those data to someone else if conditions set out by GDPR are met (right to data portability)
- to withdraw the consent at any time without affecting the lawfulness of processing based on consent before its withdrawal by contacting us about your consent withdrawal via e-mail address stated above. Regarding revoking your consent with using cookies please see our Cookie Policy.
- to object to the processing of your Personal Data based on our legitimate interest (or legitimate interest of the third party, if applicable)
- to lodge a complaint with a respective supervisory authority if you are of a view that your rights may have been infringed.
For the above purpose you may contact the Czech Data Protection Authority:
Úřad pro ochranu osobních údajů
Pplk. Sochora 27
170 00 Praha 7
the Czech Republic
Or you can also lodge your complaint with a respective supervisory authority in the EU Member State where you are usually resident, where you work or where the place where your rights are allegedly infringed is located.
Cookie Policy
What are cookies?
A cookie is a small data file (various long strings of numbers and letters) that is stored in the web browser of a website user by the website platform visited. Cookies store and transmit information to the server of the web platform that the user (repeatedly) visits from that web browser/computer. A cookie may have a limited lifetime.
What types of cookies do we use?
Technical - cookies that we necessarily need for the proper functioning of our website and all its functionalities, i.e. for the search to work properly, so that you do not have to re-enter your data in forms, so that the website remembers your login to your account, etc.
Your consent is not required for the storage and use of technical cookies. You can disable the storage of cookies at any time in your web browser settings. However, if you disable the storage of cookies, most of the basic functionalities of our website will not function properly and it will not be possible for you to make proper use of our services available to you once you have logged into your account.
Analytical - these cookies help us to analyse traffic to our website and the interaction of users of our site with its content, and to improve our site so that you can get the best experience from it. We only use these cookies if you give us permission (consent) to do so.
Marketing - we use these cookies to show you a variety of interesting marketing content, benefits, promotions, and other offers that may be of interest to you. We only use these cookies if you give us permission to do so.
It cannot be ruled out that some of the information obtained from cookies could theoretically potentially be linked to Users' Personal Data if the User is registered on our Site and is logged into their account. However, we do not make these links.
How long do we use cookies?
- Session cookies
Session cookies (temporary cookies) only exist in temporary memory for as long as the user is on the website. Web browsers usually delete session cookies when the user closes the web browser. Unlike other cookies, temporary cookies do not have a set expiry date, which is the basis for the browser to recognise that they are session cookies.
- Permanent cookies
Unlike expiration after closing the web browser - as in the case of temporary cookies - a persistent cookie expires on a specific date or after a specific period of time. This means that for the entire validity period, the cookie will transmit information to the server each time you visit the website.
If you have any questions, please contact us at any time at privacy@deepwaters.xyz.
What else is important?
We may need to update this Privacy Policy from time to time to keep pace with changes on our Site or our Services or secure full legal compliance. We will notify you of any changes by posting the updated Privacy Policy on our Site www.deepwaters.xyz. In case of material changes we may notify you also via e-mail.
By your continued use of our Services or Site after the notified changes means that you agree with the updated Privacy Policy as a whole.
This Privacy Policy is always available on our Site www.deepwaters.xyz.
Updated on 1. January 2023
