We use cookies to analyse website traffic and how our website is used, in order to make the navigation of our website easy and safe for our users. For these reasons, we may share your site usage data with our analytics partners. By clicking "Accept" you consent to the use of cookies. For more information, please refer to our Privacy Policy.

VAL

Virtual Assets Lab Privacy Policy

Last modified: September 5, 2024

Shape

Welcome to Virtual Assets Lab! We respect and protect the privacy of those who visit our website ("Visitors").

This Privacy Policy explains how Virtual Assets Lab AG and its subsidiaries, (collectively, "VAL", the "Company", "we", "us" or "our") collect, share, use, store, and protect your personal information when you visit our website (www.val.com) (the "Site"). Contact details are provided below.

Please read this Privacy Policy carefully to understand our policies and practices, as it provides a general overview of our privacy practices regarding your personal information. You can learn more about certain jurisdiction-specific information in the applicable sections of this Privacy Policy, including information for individuals residing in the European Economic Area ("EEA"), Switzerland, the United Kingdom, and California.

This Privacy Policy does not apply to websites, applications, or services that are not linked to this Privacy Policy or to those operated by third parties.

VAL Companies, Contact Information and Data Protection Officer(s)

You can check which VAL entity controls your personal information when reviewing the applicable Terms of Use of the product or service you're using, and this entity is considered a controller of your personal information and documentation (collectively, your "Personal Information").

If you have any questions with regards to this Privacy Policy or the processing of your Personal Information, we advise you to contact us using the contact information below:

VAL Companies ("Controllers")Contact Information
Virtual Assets Lab AG[email protected]
[email protected]

INFORMATION WE COLLECT ABOUT YOU

We collect Personal Information including, but not limited to, the following:

  1. Information You Provide Us
Information CategoryDescription
Basic Visitor InformationFirst Name, Last Name, and Email Address
Additional information you submit to usCommunications: Survey responses, information provided to our Support team
  1. Automatically Collected Personal Information
Information CategoryDescription
Browser, and device information

Information about the device, operating system, and browser you're using other device characteristics or identifiers (e.g. plugins, the network you connect to)

IP address

Site Usage Information

Activity Information: Information about what you view or click on while visiting our Site

Diagnostic and Troubleshooting Information: Information about how our Site is performing when you access it, i.e. website-related diagnostic and performance information, including timestamps, crash data, performance logs, and error messages or reports

Information from cookies and similar technologiesSee our Cookies Policy below for more information
  1. Information We Obtain from Affiliates and Third Parties
Information CategoryDescription
VAL Group of Companies ("Affiliates")We may obtain information about you, such as Basic Visitor Information from our Affiliates as a normal part of conducting business
Information from Analytics ProvidersWe receive information about your Site usage, interactions, age group, and survey responses (including prior to account creation, in some cases)

HOW WE USE YOUR INFORMATION

We use your Personal Information to deliver, personalize, operate, improve, create, and develop our Site, and for legal compliance, anti-money laundering, and anti-fraud purposes.

  1. Necessary to perform our contract with you

Certain Personal Information is necessary to perform under our applicable Terms of Use or other applicable contracts with you. Your account will be terminated if we cannot process your Personal Information for these purposes.

How and Why We Use Your InformationInformation Categories
To provide support

To address your request for support via the Site, or by email and to respond to support and other inquiries, and social support.

Basic Visitor Information, Site Usage Information (including Location Information), Communications
To send communications

To send you administrative or marketing related communications about our future services, which can include security updates, through email, telephone, or in-product notifications. You may not opt-out of receiving critical service communications, such as emails sent for legal or security purposes.

Basic Visitor Information, Site Usage Information, Communications
  1. To comply with our legal obligations

Our Site is subject to laws and regulations requiring us to collect, use, and store your Personal Information in certain ways. We will close your account if you do not provide the necessary Personal Information as is required by law.

How and Why We Use Your InformationInformation Categories
To comply with other legal and regulatory obligations

We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with the law, legal obligations, regulations, law enforcement, governmental, and other legal requests, court orders, or for disclosure to tax authorities.

Examples of laws that may require us to collect, use or disclose your information:

Civil, commercial, criminal, or consumer protection matters: where we are in receipt of a court order to disclose information for the purposes of court proceedings or regulatory inquiries (e.g. orders or mandatory requests under the Irish Competition and Consumer Protection Act 2014, US federal and state consumer protection and privacy laws, subpoenas from any court with jurisdiction, and/or Swiss Federal Act on Data Protection ("DPA").

Basic Visitor Information, Site Usage Information, Communications
  1. For our Legitimate Interests

We rely on our legitimate interests or those of third parties (like our other Visitors and in some cases, the general public) where they are not outweighed by your rights and freedoms. In the EEA and UK, you have the right to object to, and seek the restriction of, this processing.

Why and How We Use Your InformationLegitimate Interests Relied OnInformation Categories Used
To customize your experience with our Site and otherwise improve our Site

We are always looking to improve the functionality of our Site. All such information is securely maintained by the Company and its service providers, and is only disclosed where permitted by law.

It is in our interest to understand how you interact with the Site in order to customize and/or improve our Site and enable accurate and reliable reporting.Basic Visitor Information, Site Usage Information, Communications
To provide marketing communications to you

We use your information to send you targeted marketing communications through email.

It is in our interest to promote our products and services that you may be interested in.Basic Visitor Information, Site Usage Information, Communications
We preserve and share information with others, including law enforcement, civil litigants, and others who may issue legal requests

Where not otherwise required by law, and depending on the circumstances, we may preserve and share your information:

- in response to requests from third parties, such as civil litigants, law enforcement, and other government authorities, for example, to assist authorities in the investigation of fraud;

- to promote the safety, security, and integrity of our Site, network, our Visitors, employees, property and the public;

- when we seek to protect ourselves in the context of litigation or other disputes, such as violations of our Terms and policies; and/or

- to respond to Visitor/claimant requests or communications

It is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of the Site, violations of our Terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, Company personnel and property), our Visitors or others, including as part of investigations or regulatory inquiries; to defend our legal rights and resolve disputes; to combat harmful conduct, to detect, prevent and address fraud, abuse, spam and other bad experiences or to prevent death or imminent bodily harm.Basic Visitor Information, Site Usage Information, Communications
To promote safety, security and integrity

We may use and analyze your information to protect the integrity of our Site. For example, we may use it to:

- log visitor reports and patterns of suspicious behavior to understand techniques being used by bad actors who may wish to interfere with the Site; and

- to identify and investigate patterns of suspicious behavior or violations of our policies and Terms.

It is in our interest and the interests of our Visitors to secure our Site and network, to combat harmful conduct, to detect, prevent and address fraud, abuse, spam and other bad experiences.Any of the categories of information listed in [Section 1. Information We Collect About You.]
To provide support

To provide communications and support through our Support team.

It is in our interest and our Visitors' interest to provide support and improve our Site.Basic Visitor Information, Additional Information you submit to us
  1. Based on your consent

When we use your information based on your consent, you have the right to withdraw your consent at any time on a go-forward basis (which will not affect our prior use of your data, based on your previously given consent).

Why and How We Use Your InformationInformation Categories Used
To enable device-based settings

Collecting information that you allow us to receive through the device-based settings you enable (such as access to your GPS location, camera or photos), which we use to provide the features or services described when you enable the setting.

Browser and device information
To provide marketing communications to you

To send you targeted marketing communications through email and in-app messages.

Basic Visitor Information, Additional information You Provide to Us
  1. To protect your vital interests
Why and How We Use Your InformationInformation Categories Used
Preserving, reviewing, and sharing information with law enforcement and others

We may preserve, review, and share information with law enforcement and others in circumstances where someone's vital interests require protection, such as in the case of emergencies. For example, where there is a risk to the well-being or life of a Visitor.

Basic Visitor Information, Communications Information

The legal bases on which we rely in your country may differ from those listed above if you reside outside the United Kingdom or EEA.

WHY AND HOW WE SHARE YOUR INFORMATION

We work with service providers, partners and other third parties to help us provide our Site, and as a result, we need to share certain information with these third parties. Here's how:

  1. Affiliates

Personal Information that we process and collect may be transferred between companies, and employees affiliated with us as a normal part of conducting business and offering our Site to you.

  1. Linked Third-Party Content Providers and Third-Party Websites

When you use third-party services (like when you connect your account with your bank account), websites that are linked through our Site, or create an account with a Third-Party Content Provider (as defined in our Terms), the providers of those services or products may receive information about you that the Company, you, or others share with them. Please note that when you use these third-party services which are not governed by this Privacy Policy, their own terms and privacy policies will govern your use of those services and products.

  1. Professional advisors, industry partners, authorities, and regulators

We share your information described in Section 1. Information We Collect about You with our advisors, regulators, tax authorities, law enforcement, government agencies, and industry partners to:

  1. Asset Transfer or Company Acquisition

We may choose to buy or sell assets and may share and/or transfer information about our Visitors in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, merged, reorganized, or if we go out of business, enter bankruptcy, or go through some other change of control or similar event, your Personal Information could be one of the assets transferred to the acquiring party.

  1. Third-Party Service Providers

We work with third-party service providers to help us provide our Site. When we share information with third-party service providers in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms and only process as necessary for the purpose of the contract. We work with different types of third-party service providers, including:

Types of Third-Party Providers We UseWhat Information We Share

Third-Party electronic ID verification service vendors, including those that process biometric information

CTF/AML service providers (for the purposes of transaction monitoring)

Data hosting service providers and payment vendors (for off-site data hosting)

Analytics providers (to understand how you use our Site)

Document repository service providers

Support vendors

Compliance vendors

Basic Visitor Information, Additional information you submit to us

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We retain your information as needed to provide our Site, comply with legal obligations, or protect our or others' interests. While retention requirements vary by country, we maintain internal retention policies on the basis of how information needs to be used. This includes considerations such as when the information was collected or created, whether it is necessary in order to continue offering you our Site, whether we are required to hold the information to comply with our legal obligations, including AML/KYC compliance or other financial regulatory obligations, or information preservation requirements. We also keep certain information where necessary to protect the safety, security and integrity of our Site, and Visitors.

We retain biometric information (as part of our retention of Supplemental Identification Information) for the period required for financial regulatory compliance or otherwise as required by applicable law. Our third-party electronic identity verification service providers retain this information for as long as set out in their applicable notices/policies.

In line with these considerations, we delete information that is no longer needed for the above purposes when you close your account, or when you request deletion of your information (which you can initiate by contacting us here: [email protected]).

We employ reasonable technical and organizational measures to retain and help protect your Personal Information from compromise, as required by applicable data protection laws.

CHILDREN'S PERSONAL INFORMATION

The Site is not directed to persons under the age of 18, and we do not knowingly request or collect any information about persons under the age of 18. If you are under the age of 18, please do not provide any Personal Information through the Site. If a Visitor submitting Personal Information is suspected of being younger than 18 years of age, the Company will take steps to delete the individual's information as soon as possible.

INTERNATIONAL TRANSFERS

To facilitate our global operations, the Company, its Affiliates, third-party partners, and service providers may transfer, store, and process your Personal Information throughout the world, including Ireland, Switzerland, the Cayman Islands, and the US.

If you reside in the EEA, Switzerland, or the United Kingdom, we rely upon a variety of legal mechanisms to facilitate these transfers of your Personal Information (collectively, "European Personal Data"). By providing Personal Information to us, you consent to the transfer of your Personal Information to such third countries. To the extent applicable, we have adopted appropriate transfer mechanisms to safeguard the transfer of your Personal Information in accordance with applicable laws, including, the European Commission's Standard Contractual Clauses.

For a copy of the Standard Contractual Clauses, please contact [email protected].

In addition, we may rely on certain exemptions provided for under data protection law for our international transfers. We also rely on adequacy decisions from the European Commission where available and exemptions provided for under data protection law. For example, because the Company operates and provides its Site globally, we need to share information with our Affiliates and to data centers outside the EEA in order to develop, offer, and improve our Site (Article 49(1)(b) GDPR). In addition, we may rely on certain exemptions for sharing Personal Information with law enforcement outside of the EEA in emergency situations (Article 49(1)(f) GDPR).

YOUR PRIVACY RIGHTS

Depending on where you live, you may be able to exercise certain privacy rights related to your Personal Information. For any of your privacy rights and choices referenced below, requests relating to your Personal Information can be made by submitting a request by contacting us at [email protected]. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, the Company has absolute discretion in providing you with these rights.

You may request that we provide you a copy of your Personal Information held by contacting us at [email protected].

You may request us to rectify or update any of your Personal Information held by the Company that is incomplete or inaccurate by contacting us at [email protected].

You may request to erase your Personal Information, subject to applicable law, by contacting us at [email protected]. If you close your account, we will retain or delete information associated with your account.

To the extent the processing of your Personal Information is based on your consent, you may withdraw your consent at any time. The lawfulness of the Company's processing before you withdraw your consent will not be affected by such withdrawal.

You may have the right to restrict or object to us using or transferring your Personal Information based on our legitimate interests, in the public interest, or for direct marketing. We may continue to process your Personal Information where permitted or required by applicable law. You can opt-out of receiving marketing communications from the Company by contacting us at [email protected].

We will not discriminate against you for exercising any of your rights provided to you under law.

If you reside in the EEA, Switzerland, or the UK, you have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or state. In the UK, the relevant data protection authority is the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, +44 (0303) 123 1113, email: [email protected]. In Ireland, the relevant data protection authority is the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, +353 017650100 / + 353 1800437737, email: [email protected].

To protect your privacy and security, we may take steps to verify your identity before complying with your request and we may decline your request if we are unable to verify your identity.

These rights are not absolute and may be denied: (a) when granting access or assisting portability would adversely affect the rights and freedoms of others; (b) to protect our rights and properties; (c) where the request is frivolous or vexatious; or (d) as otherwise permitted by law.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This California Privacy Notice ("Notice") is for California residents, and describes how we collect, use, and share your Personal Information. This Notice supplements our Privacy Policy. Any terms defined in the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020) ("CCPA") have the same meaning when used in this Notice.

The CCPA, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act. The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with you.

Sources of Personal Information. We gather various types of Personal Information from our Visitors, individuals who access or use our Site, from a range of sources, such as:

Purpose for Collection and Disclosure of Personal Information. We've collected and disclosed the below categories for Personal Information to create, develop, operate, deliver, and improve our Site, to communicate with you, to ensure the safety, security and integrity of our Site, and for the business and commercial purposes. We do not collect, use, or disclose sensitive Personal Information for purposes other than those specified in this privacy policy, to provide the Site, or as permitted under applicable law.

Collection and Disclosure of Personal Information. In the past 12 months, we may collect, and have collected, the below categories of Personal Information, and disclosed the specific types of Personal Information below (as that data is further referenced and outlined herein) with the following categories of third parties:

Category of Personal Information as outlined in the CCPAInformation Collected and DisclosedCategories of Recipients
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers

Basic Visitor Information

Supplemental Identification Information

Electronic Identification Information

Institutional Information

Financial Information

Third party identity verification services

Financial institutions

Service providers

Professional advisors

Our Affiliates

Personal information described in subdivision (e) of Section 1798.80 (e.g., name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information)

Basic Visitor Information

Supplemental Identification Information

Electronic Identification Information

Institutional Information

Financial Information

Third party identity verification services

Financial institutions

Service providers

Professional advisors

Our Affiliates

Protected classifications under California and federal law, including gender, age, and citizenship

Supplemental Identification Information

Electronic Identification Information

Third party identity verification services

Professional advisors

Biometric informationElectronic Identification Information

Third party identity verification services

Financial institutions

Professional advisors

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement

Product Usage Information

App, browser, and device information

Information from cookies and similar technologies

Third party identity verification services

Service providers

Professional advisors

Our Affiliates

Geolocation dataApp, browser, and device information

Third party identity verification services

Service providers

Professional advisors

Sensory information, such as audio, electronic, visual, thermal, olfactory, or similar information (e.g., recorded meetings and phone calls)

Call and video recordings

Communications

Third party identity verification services

Service providers

Professional advisors

Our Affiliates

Professional or employment related information

Institutional Information

Direct deposit

Salary

Third party identity verification services

Service providers

Professional advisors

Our Affiliates

Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; interaction data collected about you when you interact with us such as websites or mobile apps including log data (information collected when you access our website including IP address, URLs and crash data), device data (information about your device including type, operating system and unique identifiers), browser data (information about your browser type, settings cookie data)Information derived from other information about you, which could include your preferences, interests, and other information used to personalize your experience or provide you our Site

Service providers

Professional advisors

Our Affiliates

Collection and Disclosure of Sensitive Personal Information. In the past 12 months, we may collect, and we have collected and disclosed the following categories of sensitive Personal Information, with the following categories of third parties:

Category of Sensitive Personal Information as outlined in the CCPAInformation Collected and DisclosedCategories of Recipients
Sensitive identifier (e.g., social security number, driver's license, state identification card, or passport number)

Supplemental Identification Information

Electronic Identification Information

Third party identity verification services

Professional advisors

Account information (e.g., account log-in, financial account, password, or credentials allowing access to an account

Supplemental Identification Information

Electronic Identification Information

Third party identity verification services

Professional advisors

Communications content (e.g., mail, email, and text messages unless the business is the intended recipient of the communication)Communications

Service Providers

Professional Advisors

Biometric information processed for the purpose of unique identificationElectronic Identification Information

Third party identity verification services

Financial institutions

Professional advisors

Retention period or criteria. We retain California resident Personal Information for a period commensurate with the purposes for which the Personal Information was collected or obtained. For example, the criteria used to determine the retention of Personal Information includes any time necessary to complete a transaction or for legal and compliance purposes or security purposes. Personal Information may be retained in archival format (e.g., data backups) beyond its retention period so long as it is not subject to further access.

Selling or Sharing of Personal Information. [In the past 12 months, we've shared (as that term is defined in the CCPA, as amended by the California Privacy Rights Act of 2020, and the CCPA Regulations) identifiers with third party service providers.

We do not have actual knowledge that we sell or share Personal Information of individuals under 16 years of age.

California Privacy Rights. Under the CCPA, eligible California residents may be entitled to certain privacy rights, including:

Exercising Your Rights. You may exercise your rights by contacting us at [email protected] and then verifying your identity (a "Verifiable Consumer Request"). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may collect information such as your email address, government issued ID, or date of birth, before providing a substantive response to the request.

We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and up to twice in twelve (12) months. We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided you receive notification of the extension within the first forty-five (45) days.

You may send us an email at [email protected] to request access to, correct, or delete any Personal Information that you have provided to us. Should you feel that your data is processed in breach of data protection law or other legislation, you can report your concern to us by emailing us at [email protected].

California "Shine the Light" Law. We do not share Personal Information, as defined by Cal. Civ. Code § 1798.83, with third parties for their direct marketing purposes.

Questions & Opting-Out. If you have questions or concerns regarding this Notice, if you want to request to opt-out of the sale or sharing of your Personal Information, or if you have a complaint, please contact us at [email protected].

U.S. STATE CONSUMER PRIVACY RIGHTS

Residents of the U.S. states of Colorado, Connecticut, Utah, and Virginia may have the following rights:

COOKIE POLICY

We use cookies and similar technologies. This Cookie Policy explains how we use cookies in connection with the Site and your related choices.

What Types of Cookies Do We Use?

Cookies are small text files that collect standard Internet log information and visitor behavior information. Cookies are stored in your web browser and allow certain websites to retrieve stored information later. When you visit our websites, we may collect information from you automatically through cookies or similar technology (collectively "Cookies").

There are a variety of different types of cookies. Our Website uses:

You can learn more about Cookies at https://allaboutcookies.org/.

HOW TO CONTACT US WITH QUESTIONS

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us at [email protected].

You can also file a complaint to your respective data protection authority in the EU, UK, or California.

CHANGES TO THIS PRIVACY POLICY

We're constantly trying to improve our Site, so we may need to change this Privacy Policy from time to time as well. We post any changes we make to our Privacy Policy on this page and, where appropriate, we will provide you with reasonable notice of any material changes before they take effect or as otherwise required by law. The date the Privacy Policy was last updated is identified at the top of this page. If your consent is required for any such changes, we will obtain your consent before such changes are applied to you.