Privacy Policy

1. Purpose

The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Site of the following:

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• The personal data we will collect;
• Use of collected data;
• Who has access to the data collected;
• The rights of Site users
• The Site's cookie policy.

This Privacy Policy applies in addition to the Terms and Conditions of our Site.

2. Consent

By using our Site users agree that they consent to:

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• The conditions set out in this Privacy Policy; and
• The collection, use, and retention of the data listed in this Privacy Policy.

3. Personal Data We Collect

We only collect data that helps us achieve the purposes set out in this Privacy Policy, or that we are required to collect and retain by law.

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Data You Provide Through the Site

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When you submit a form, book an appointment, or contact us through the Site, we may collect:

• First and last name;
• Email address;
• Phone number.

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Data We Collect to Meet Our Compliance Obligations

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COINworKs Inc. is a Money Services Business registered with the Financial Crimes Enforcement Network (“FinCEN”). To transact with us, and as described in Section 3 of our Terms of Service, we are required to collect and verify:

• Your first and last name;
• SMS phone verification;
• A copy of your driver’s license or other government-issued identification card;
• Where required, your Social Security Number or Taxpayer Identification Number;
• Records of your transactions with us, including amounts, dates and wallet addresses you provide.

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We use this information to verify your identity, to perform OFAC and other watchlist screening, and to meet our recordkeeping and reporting obligations under the Bank Secrecy Act, including filing Currency Transaction Reports where required. We do not use identity verification documents for marketing.

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Data Collected Automatically

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When you visit the Site we and our analytics and advertising providers automatically collect device and usage data, including IP address, browser and device type, pages viewed, referring URL, and interactions with the Site, through cookies and similar technologies. See Section 12 for details.

4. How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect when the user performs certain functions may be used for the following purposes:

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• To contact and communicate with customers and/or prospective customers
• To periodically send marketing materials.

5. Who We Share Personal Data With

Employees

We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Third Parties

We may share user data with the following third parties:

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• Google Ads;
• Google Analytics;
• Meta (Facebook) advertising and measurement;
• Microsoft Clarity;
• Service providers that support our operations, including our scheduling, email and hosting providers;
• Regulators, law enforcement and financial institutions, where we are required to report or disclose information under the Bank Secrecy Act or other applicable law.

We may share the following user data with third parties:

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• Site usage data.

We may share user data with third parties for the following purposes:

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• Improvement of advertising.

Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.

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Other Disclosures

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Apart from the advertising and analytics providers named above, and the sharing for cross-context behavioral advertising described in Section 15, we will not sell or share your data with other third parties, except in the following cases:

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• If the law requires it;
• If it is required for any legal proceeding
• To prove or protect our legal rights
• To buyers or potential buyers of this company in the event that we seek to sell the company.

We never sell your personal information for money, and we do not sell or share the personal information of anyone we know to be under 16 years of age. You can opt out of the advertising sharing at any time on our Your Privacy Choices page.

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

6. How Long We Store Personal Data

We retain personal data only for as long as we need it for the purpose it was collected, or for as long as the law requires us to keep it. Our retention periods are:

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• Transaction and identity verification records — five (5) years following the date of the transaction or the closure of your relationship with us, whichever is later. This period is set by the recordkeeping requirements that apply to us as a FinCEN-registered Money Services Business under the Bank Secrecy Act, and we cannot delete these records earlier on request.
• Website contact form and enquiry data — twenty-four (24) months from your last interaction with us, unless it forms part of a transaction record.
• Marketing and email list data — until you unsubscribe or ask us to remove you, and then no more than twelve (12) months in a suppression record so that we do not contact you again.
• Website analytics and advertising data — in line with the retention settings of the providers listed in Section 5, and no longer than twenty-six (26) months.

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When a retention period ends, we delete or de-identify the data. If you ask us to delete your data, we will do so except where we are legally required to retain it, and we will tell you if that is the case.

7. How We Protect Your Personal Data

In order to protect your security, we use the strongest available browser encryption and store all of our data on servers in secure facilities. All data is only accessible to our employees. Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee's termination.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

8. Children

We do not knowingly collect or use personal data from children under 13 years of age. If we learn that we have collected personal data from a child under 13 years of age, the personal data will be deleted as soon as possible. If a child under 13 years of age has provided us with personal data their parent or guardian may contact our privacy officer at info@thebitcoinstore.com.

9. How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, or if you would like your data to be deleted or modified in any way, please contact our privacy officer at info@thebitcoinstore.com.

10. Do Not Track and Opt-Out Preference Signals

Do Not Track ("DNT") is a privacy preference that you can set in certain web browsers. There is no common industry standard for how DNT signals should be interpreted, and our Site does not respond to browser-initiated DNT signals.

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Our Site uses analytics and advertising technologies, including those listed in Section 5, that collect information about your activity on our Site and may combine it with information collected on other websites for measurement and advertising purposes. Under California law this may be considered “sharing” personal information for cross-context behavioral advertising.

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We honor the Global Privacy Control (“GPC”) opt-out preference signal. If you visit our Site with GPC enabled we detect it before any tracker loads and treat it as a request to opt out of the sale or sharing of your personal information from that browser, with no further action needed from you. You may also opt out directly on our Your Privacy Choices page, or using the methods in Section 15. We are not responsible for and cannot guarantee how any third parties who interact with our Site and your data will respond to DNT or GPC signals.

11. How to Opt-Out of Data Collection, Use or Disclosure

In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:

1. Any data submitted on website forms or email lists. You can opt-out by contacting us at info@thebitcoinstore.com to remove or edit data. To opt-out of our email list you may use the unsubscribe link on our website, or email us at info@thebitcoinstore.com

12. Cookie Policy

A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

We use the following types of cookies on our Site:

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Analytics Cookies

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Analytics cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc.

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Targeting Cookies

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Targeting cookies collect data on how you use the Site and your preferences. This allows us to personalize the information you see on our Site for you.

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Third-Party Cookies

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Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:

1. Better understand use of the website in order to improve user experience and advertising outreach.

13. Modifications

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

14. Contact Information

If you have any questions, concerns or complaints, you can contact our privacy officer at: info@thebitcoinstore.com.

15. Your California Privacy Rights

This section applies to California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”). It supplements the rest of this Privacy Policy.

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Notice at Collection

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The categories of personal information we collect, the purposes for which we use them, and how long we keep them are described in Sections 3, 4 and 6. In summary, we collect identifiers (name, email, phone, IP address), government identification numbers and documents, financial and transaction information, and internet activity information. We collect this information to provide our services, to verify your identity and meet our legal obligations as a Money Services Business, to communicate with you, and to measure and improve our advertising.

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Sale and Sharing of Personal Information

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We do not sell your personal information for money. We do share internet activity information with the advertising and analytics providers listed in Section 5 for cross-context behavioral advertising, which California law treats as “sharing.” We do not sell or share the personal information of consumers we know to be under 16 years of age. We do not sell or share your identity verification documents or transaction records.

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Sensitive Personal Information

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We collect government identification numbers, including driver’s license and, where required, Social Security or Taxpayer Identification Numbers, which California law treats as sensitive personal information. We use this information solely to verify your identity and to meet our legal and compliance obligations. We do not use or disclose it to infer characteristics about you, and we do not use it for advertising.

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Your Rights

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Subject to verification and to the legal exceptions described below, you have the right to:

• Know what personal information we have collected about you, the sources, the purposes, and the categories of third parties we disclose it to;
• Access a copy of the personal information we hold about you;
• Delete the personal information we have collected from you;
• Correct inaccurate personal information we hold about you;
• Opt out of the sale or sharing of your personal information;
• Limit our use of your sensitive personal information;
• Non-discrimination — we will not deny you services, charge you a different price, or provide you a different level of service because you exercised any of these rights.

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How to Exercise Your Rights

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Email info@thebitcoinstore.com or call (888) 811-2646. To opt out of the sale or sharing of your personal information, use the Your Privacy Choices page, which switches off our advertising and analytics trackers in that browser immediately. You can also email us with the subject line “Do Not Sell or Share My Personal Information,” or browse our Site with the Global Privacy Control signal enabled as described in Section 10.

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We will confirm receipt of your request within 10 business days and respond within 45 calendar days, and we will tell you if we need a further 45 days. To protect your information, we will need to verify your identity before acting on a request to know, access, delete or correct. An authorized agent may submit a request on your behalf with written permission that we can verify.

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Limits on Deletion

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We cannot delete transaction and identity verification records before the end of the five-year retention period described in Section 6, because federal recordkeeping requirements that apply to us as a FinCEN-registered Money Services Business override a deletion request. If we deny a request on this basis, we will tell you why.

16. Governing Law

This Privacy Policy, and any dispute arising out of or relating to it or to our handling of your personal information, is governed by and construed in accordance with the laws of the State of California, without regard to its conflict of law rules. Nothing in this Privacy Policy waives any right or remedy available to you under the California Consumer Privacy Act or any other California law that cannot be waived.

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Where this Privacy Policy and our Terms of Service conflict on the handling of your personal information, this Privacy Policy governs.