Last Updated: Feb 28, 2022
EU-U.S. Privacy Shield Framework
What Information We Collect; the Purpose of Collection and Use
We collect the following categories of information. Subscribers of our Services (“Subscribers”) authorize the collection, processing, and transfer of such information, and assume contractual responsibility for providing notification to Subscriber’s customers who are end-users of the Services and obtaining all consents as required under applicable laws and regulations.
Contact Information: We collect contact information on our Site from visitors, and customers who wish to obtain information or support, purchase our Services or receive our newsletter. Contact information is provided via browser forms or online forms and includes first name, last name, e-mail address, name of the organization, and country (“Contact Information”). This Contact Information is used by our sales, support, and product teams to contact our Site visitors and customers, as appropriate, for the purpose of providing the requested information, support, Services, newsletters, or other news, materials, or updates regarding our Services.
Service Information: In the course of performing our Services, we collect the following categories of information (collectively, “Service Information”).
End-User Information: End-User means (i) Subscribers’ customers who are end-users of our Services; and (ii) all customers of Fundamental Interactions’ other Subscribers who seek to enter into Transactions (as defined below) through the Services. We may collect limited End User information at the direction of our Subscribers. Where we have End User information it is limited to IP addresses and e-mail addresses. Subscribers may, at their discretion, prefer to keep all End User information private consistent with their internal policies. Alternatively, Subscribers may utilize the functionality to collect limited private information (which is only accessible in a Subscriber’s environment). End-User information is used to operate, maintain and improve the Services.
Transaction Information: We collect transaction-related information for transactions conducted by End Users through the Services (“Transactions”) but it is anonymized. Transaction information includes price, quantity, and any associated or supporting data related to the trade. Transaction information is used to provide the Services, facilitate the Transactions, provide support, and operate, maintain and improve the Services.
Billing Information: We collect billing and payment information which may include a purchase order number, an account number, credit card number, expiration date, billing zip code, bitcoin-related information, instructions for wire transfers, and/or ACH transfers (“Billing Information”) from Subscribers (and not End- Users). Billing Information is collected and processed by our third-party payment processor operating as our agent (See, Onward Transfers to Third Parties). Fundamental Interactions does not directly obtain or process any Billing Information; except in the case of ACH transfers in which case we obtain the Billing Information related to ACH transfers and send (not store) it to our third-party bank processors operating as our agent (See, Onward Transfers to Third Parties).
Other Information: In addition to the Contact Information, Service Information, and Billing Information, we may collect or receive the following information:
From Your Activity. In an ongoing effort to improve the Site and the Services, we automatically collect certain information when visitors visit the Site and when Subscribers and End Users use the Services. This information consists of IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Site visitors visit, and similar information concerning your use of the Site and the Services.