Privacy Policy

 

BitRail Privacy Policy

Introduction

BitRail wants you to understand what kinds of information it collects on its Website, and how it uses, shares, and protects that information.  The following discloses BitRail’s information gathering and dissemination practices for the Site and BitRail Mobile Applications.  As used in this Privacy Policy, “we”, “us”, and “our” refers to BitRail, LLC and the “Site” refers to www.bitrail.io and its subdomains.  

The Site resides on servers located in the United States of America.  If you are located outside the United States, please be aware that information you provide on the Site is being transferred to and stored in the United States.  Use of BitRail services is only available to persons located in the United States.  The Site’s personal information practices and the terms of this Privacy Policy may or may not comply with foreign law, so if you do not agree with this, please do not use the Site or our services.

This Policy is broken down into several Sections.  You can follow the links below to a particular Section or read the entire policy here.

 

Table of Contents

General

Information We Collect on the Site and How We Use It

How We Share Your Information

Communications From the Site and Your Choices

Children’s Privacy

For Persons Outside the United States

Security of Your Personal Information

Acceptance of this Privacy Policy

Contacting Us

Changes to this Privacy Policy

General
The information we learn from customers helps us improve your BitRail experience. Below is a list of definitions for some of the terms used in this Privacy Policy:

Personal Information means information that may be used to identify a specific individual, or that is about an identifiable individual, including but not limited to name, email address, mailing address, mobile phone number, bank account number and balances, and social security number.

Aggregate Information refers to combined demographic information which has been derived from Personal Information, but which cannot be reasonably used to identify any individual.

Transaction Information includes certain information about a transaction conducted on our Site, including all purchases, shipping information, billing and payment information, and other information you provided in connection with a transaction as required by law.

Mobile Phone Subscriber Information may include, without limitation, a user’s name, date of birth, postal address, billing zip code, telephone numbers, electronic mail addresses, credit card numbers, Customer Proprietary Network Information (CPNI), location information, handset and mobile device identifiers (International Mobile Subscriber Identity (IMSI) and International Mobile Equipment Identity (IMEI)), and other status details, if available, such as account information and credit information.

Affiliates are companies related by common ownership or control, which may include financial or non-financial companies.  Non-Affiliates are companies not related by common ownership or control.

Joint Marketing Partners refers to Non-Affiliate companies that have a formal agreement with us to jointly market financial or other products or services to you. We do not have any Joint Marketing Partners.

 

I. Information We Collect On the Site and How We Use It

You can visit our Web Site and learn about the services we provide without providing Personal Information.  You do need to provide Personal Information, however, to use our services.  Certain items of non-personally identifiable information, such as IP address, are collected automatically from every Site visitor, even if not voluntarily provided, as discussed further below.

We collect and use Personal Information in the specific ways listed below, and generally to improve our Site and services to you, as well as to meet our legal obligations.  We also use Personal Information you provide for other purposes consistent with the reason you provide such information to us.  For example, we may collect certain Personal Information that you provide through correspondence, customer service requests, or dispute resolution activities.

Registration and Site Activity Information.  The Site’s account registration process requires users to provide us valid and accurate contact information including full name, email address, a user name of your choosing, and a password (collectively, “Registration Information”).  In addition, if you do not choose a user name, a user name will be assigned to you.

At this time, whether you wish to use the Site as an individual or in connection with a business that you represent, we verify your eligibility for an account in your individual capacity.  We verify your account registration information through a third-party identity verification service provider. This is done if you are an individual user or represent a business user to verify your identity and prevent fraud.

Our third party identity verification provider uses your Mobile Phone Subscriber Data, as defined above, from your mobile carrier (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless carrier) to verify your identity and provide BitRail your mailing address, your Social Security Number (SSN) and a “Trust Score”.  BitRail does not store your full SSN, only the last 4 digits.  The “Trust Score” is a measure of the degree of confidence that you are a real person associated with the address you provided, and it does not relate to your credit or payment history.

Pre-Fill Form Option: Identity verification using your Mobile Phone Subscriber Data includes a Pre-Fill Form Option for us to use to expedite verifying your identity by using information verified by our third party identify verification provider. The Pre-Fill Form Option requires you to answer a question by submitting your mobile phone billing zip code. It also requires you to provide us your express opt-in consent by clicking on the “OK” button on the consent page.

You authorize your wireless operator to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber details, if available, to BitRail and service providers for the duration of the business relationship, solely for identity verification and fraud avoidance.

If you are registering your account using the BitRail website and you prefer that BitRail not use a third party provider to verify your identity, you may provide BitRail verification of your name and address by uploading a scan of two approved documents, such as your driver’s license or a utility bill. If you are registering your account using a BitRail Mobile Application, verification of your identity by third party provider is automatic and you may not opt out of this identity verification service.  

BitRail verifies your email address by sending you an email with a link for you to click on to confirm that it is your correct email address.  You will not be permitted to use BitRail until your email address has been verified to BitRail’s satisfaction.

Registration Information, Transaction Information and other Personal Information that you provide may be used to:

  • provide the services and customer support you request;
  • process transactions on the Site;
  • compare information for accuracy and share it with third parties to prevent fraud, prohibited or illegal activities;
  • send you transaction-related notifications about transactions you carry out on the Site;
  • If and when you purchase on an item, to provide your name, address, telephone number, email address to the seller to facilitate the transaction;
  • Enforce our Term and Conditions of Use and perform our billing, administration and collections functions (and to contact you when necessary about these functions);
  • report information about your account, including late payments, missed payments or other delinquencies or defaults on your accounts, to credit reporting bureaus;
  • better understand your interests and for other marketing-related initiatives including customizing, personalizing, measuring, and improving our services and the content and layout of our Site and/or Mobile Applications;
  • communicate with you and carry out actions requested by you (such as subscriptions to newsletters), including promotional messages and service and product updates (some of which may be related to your transactions on the Site);
  • resolve disputes, collect fees and trouble-shoot problems;
  • when facilitating the investigation of fraud or illegal activity, to share information with law enforcement or other governmental agencies or authorized third parties when requested pursuant to a criminal investigation or alleged illegal activity or any other activity that may expose you, us or another Site user to legal liability;
  • perform other duties as required by applicable law.

You can review your Personal Information by logging into our Site, and you should act to update it promptly when it changes or to correct any errors in it.  However, you will not be able to change your mailing address.  

At your request, we will close your account as soon as reasonably possible, in accordance with applicable law.  

Please see “Communications From the Site and Your Choices” below for information on controlling communications from us.

2.   Personal Financial Information.  If you use our services, you must provide us financial information about the U.S.-based bank account you want to use for your BitRail transactions including your bank account number, type of bank account, bank routing number, and billing address (“Personal Financial Information”).  Only the last 4 digits of your bank account number are visible to BitRail employees in the course of performing support and rendering the BitRail services.  This Personal Financial Information is used to facilitate transactions you carry out on the Site and to collect on fees and debts incurred through your use of the Site.  If your account is past due and collection must be pursued, your contact and financial information may be shared with collection agents and/or credit reporting agencies.  We share Personal Financial Information with non-affiliated third parties to facilitate the completion of transactions on the Site as specified above, to respond to subpoenas, for other legal compliance purposes, and for billing and collections.

3.   Information Requests.  We may ask you to provide Personal Information in order to allow us to respond to your requests for information or other requests made over the Site.

4.  Communications from BitRail.  Most messages, notifications and communications generated by the Site result directly from the user’s actions (such as account Registration Information, confirmation of a transaction, or the user’s choice to subscribe to certain communications), or as necessary to inform you of changes to the Site or events related to the Site, or changes to the Site rules or policies. Other messages may result from marketing initiatives on the Site; however, users may opt-out of receiving marketing messages; see the section below entitled “Communications from the Site and Your Choices.”

Communications from our Site may contain web beacons or “clear.gif” images.  These are small, usually transparent graphic images that can be used for recording when a message has been opened in order to track the performance of marketing campaigns.  We and our third-party service providers currently log responses using web beacons, but this information is not stored or linked to your Personal Information in our systems.

5.   Non-personal information.  We automatically collect your IP address when you visit our Site or use our service.  We use your IP address to verify your identity, prevent fraud and restrict your use of our service in some geographic areas such as outside the United States.  We also use your IP address to help diagnose problems with our server, and to administer our Site. Your IP address is used to gather broad demographic information, and to track usage patterns in the Site. We also may collect geo-location information, device identification number, statistics about page views and standard web log information.   We do not correlate this information with data about individual users (though our third-party website analytics service providers may – see below under “Website Analytics” for your choices in this regard).

6.   Cookies.  We or our third-party service providers may use a technology referred to as “cookies” (or other similar technology), which are pieces of data on your computer tied to information about you. Based on your browser type and other information provided by our cookies, we use cookies to: (i) customize certain Site content and access; (ii) track usage patterns on the Site; (iii) allow the Site to remember your user name and password if you so choose; and (iv) for any other purposes permitted under applicable law from time to time.

You can decide if and how your device will accept cookies by configuring your preferences option within your web browser.  To disable this function in your web browser, choose the “help” menu and follow the instructions for deleting cookies and preventing your browser from downloading additional cookies. If you choose to reject cookies, you can still browse our Site, but you may be unable to use the Site as a buyer, or otherwise to access certain aspects of the services available on the Site.  We do not store personal or confidential information in cookies (although our third- party Website Analytics provider may do so. )

7.   General Uses.  In addition to the foregoing, we will use your Personal Information as specifically described on the Site at the time of collection.  We may also use your Personal Information internally to customize your experience with our company and our Site (for example, adapting the Site to your browser), to help us develop new products and services, to verify your identity, to collect debts or fees owed to us, or to investigate or settle inquiries or disputes, and for other legally required or permissible purposes.

8. Website AnalyticsWe use Google Analytics to help us measure visitors and trends for our websites. For more information about how Google collects, uses and shares your information, please visit the Google Privacy Policy-Partners website at http://www.google.com/policies/privacy/partners/.   To prevent your data from being used by Google Analytics, click here for instructions.

9. Mobile Devices.  In addition to the information described above, we and our third-party service providers may collect additional information when you utilize any of our mobile applications, including the temporary or persistent unique device identifiers (sometimes called UDID), the IP address of your mobile device and information about the way you use our mobile applications.

II.    How We Share Your Information

At your direction, when you authorize an account connection on the Site between BitRail and a bank account you lawfully control or own and which you registered on the site, BitRail and your bank will exchange Personal Financial Information necessary to complete your transactions on the Site.  Personal Financial Information exchanged between BitRail and your registered bank account may include account balance and account and transactional information such as purchases and funds transfers. Before authorizing an account connection between BitRail and your bank, you should review your bank’s privacy notice.  

Similarly, at your direction, when you authorize the purchase of one or more denominations of a participating cryptocurrency (“Coins”) on the Site, BitRail and the issuer of the Coins (in the case of FreedomCoins, BitRail) or a third-party depositary company of Coins will exchange Personal Financial Information necessary to complete your transactions on the Site.  Personal Financial Information exchanged between BitRail and the Coin issuer or depositary company may include account balance and account and transactional information such as purchases and funds transfers. Before authorizing an account connection between BitRail and any Coin issuer or depositary company, you should review such third party’s privacy notice. We will use only use your Personal Financial Information in ways that are consistent with this privacy policy.  

Other than as described above, with your express consent or as specifically described elsewhere in this Privacy Policy, we will not share your Personal Information collected on the Site with third parties without your permission, except as necessary or appropriate to (i) carry out the transaction, activity or request made by you on the Site or otherwise, (ii) comply with any applicable law, court order or other judicial process, or (iii) enforce or apply agreements with you, or protect the rights, property or safety of us, our affiliates or third parties, or as otherwise required or permitted by law.

We do not share your Personal Financial Information with any other third parties including sellers, buyers, other recipients of funds, or third-party websites or mobile apps hosting purchase/sale transactions or other transfers.  The only information that is shared in a transaction using our services is that a transaction occurred in a specified amount of US Dollars or a specified number of Coins (“Purchase Data”). That Purchase Data is shared with the involved parties to the transaction and the hosting website or mobile application as part of the Site’s operation, but please note that users of the Site are able to fill in information that they choose in a blank “description” field provided on the Site, so other users may input other data into this custom field.  If you contact BitRail customer support regarding a transaction, the helpdesk will have access to all your account and transaction information and possibly your location if you disclose that to them.

In the event of a corporate transaction such as a sale, merger or reorganization or in the unlikely event of a bankruptcy or similar restructuring involving all or a portion of BitRail, LLC or its parent and/or Affiliate(s) (including but not limited to a spinoff of an Affiliate, and subsequent acquisition of that Affiliate by a new third party), or a sale or transfer of assets, we reserve the right to disclose or transfer your Personal Information to non-affiliated third-party acquiring company(ies) and other third parties.  In the event of such a sale or transfer, we will use reasonable efforts to direct the transferee(s) to use Personal Information you have provided through this Site in a manner that is consistent with this Privacy Policy.  We may collect and share aggregate information (such as sales, traffic patterns or related information) with third parties.

We hire contractors to provide certain services on our behalf, including trend and statistical analysis, marketing campaigns, information processing and storage, and development of new products and services.  As part of their services to us, these contractors may have access to some or all of the data that we maintain, including transaction data and your Personal Information, but they are always required to maintain the confidentiality of information they receive from us and are restricted from using the information for any purposes other than those authorized by us. 

We do not share your Personal Information with any third parties for such third parties’ marketing purposes, unless you have opted into such sharing.

Except as otherwise provided, this Privacy Policy only addresses the information that we collect from you, but not about how third parties to whom you disclose your information may use and disclose it.  If you disclose your Personal Information to third parties such as sellers, other rules may apply to how they use and disclose information provided to them.  We do not police or influence the privacy practices of third parties.  When providing your Personal Information to third parties, their privacy policies govern their use and disclosure of your Personal Information.  Before disclosing your Personal Information to a third party, you should familiarize yourself with their privacy policy.  When Users transact with each other, they may have access to each other’s name, user ID information, email address and other contact information.  By using our Site, you agree to use other Users’ information only for BitRail transaction-related purposes or other purposes for which a User explicitly chooses. 

III.   Communications From the Site and Your Choices 

1Email and Text Messages from Us.  The Site sends two types of communications: (1) email and/or text message notifications related to transactions on the Site, and (2) promotional email and/or text messages, which may include newsletters or other subscription-based communications, follow-on messages with respect to your activity on the Site, or other marketing from us about our products and services. Please see the descriptions below with respect to your choices for each.

(1)  Transactions on the Site.  Email and/or text messages related to activity on the Site are generated as a result or registering as a user of the Site, and for conducting transactions. These notifications can include transaction notifications, billing messages, and other notifications related to activity on the Site. You cannot opt out of receiving email notifications related to transaction activity on the Site.  You cannot opt out of receiving messages by email and/or text as part of our two-factor authentication process.  Every time you log-in using a mobile phone, you will be required to complete our two-factor authentication process, which includes email and text messages.  You will not receive any other types of text message notifications from us.

We may also send you certain notices, such as notices of a substantial change in the policies and/or operation of the Site. These notices are sent infrequently and cannot be opted out of other than by closing your account with us.

(2)   Promotional Email and/or Text Messages.  BitRail may send a variety of promotional email messages, but you are free to opt out of these at any time.  Some promotional email messages relate to newsletters or other subscription-based items.  If you would also like to receive these notifications from us by text message, you may opt-in to receiving text messages by logging into My BitRail Account and visiting the Preferences page to update your choices to opt-in to receiving promotional text messages from us.  

You may also control receiving promotional emails at any time by logging into My BitRail Account and visiting the Preferences page to update your choices.  You may also click here and follow the instructions on the subsequent pages to opt out of promotional email or text messages, or follow the instructions provided in the promotional message.

2. Cookies and Third-Party Tracking.  As noted above under “Website Analytics” we contract with a third-party service provider who provides us information on the use of the Sites by visitors.  As described in that section, you may visit certain designated Web sites in order to opt out of tracking of your activities on the Sites and other Web sites.

Notwithstanding any other provision, we may engage a data provider who may collect web log data from you (including IP address and information about your browser or operating system), or place or recognize a unique cookie on your browser to enable you to receive customized ads or content through web, mobile or other media channels. These cookies contain no personally identifiable information. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, that we may share with a data provider solely in hashed, non-human readable form. To opt-out of these data provider cookies, please visit http://www.aboutads.info/choices or http://www.networkadvertising/choices.

We may work with online advertising vendors to provide you with relevant and useful advertisements, including ad content displayed in our email messages to you.  These advertisements may be based on information collected by us or by third parties, including information about your activities on our Site or on third-party websites.  You may opt out of personalization of these messages by visiting the opt-out sites referenced in the paragraph above.

IV.   Children’s Privacy

The Site is not intended for or directed to persons less than 18 years of age.  The BitRail Mobile Applications are likewise not intended for or directed to persons less than 18 years of age.  We do not knowingly solicit or collect personal information from or about persons under 18, and we do not knowingly market or sell products or services to persons under 18.  If you are under 18 years of age, do not use the Site or the BitRail Mobile Applications.

Similarly, of course, the Site is not intended for or directed to persons less than 13 years of age.  In accordance with the Children’s Online Privacy Protection Act (COPPA), we do not knowingly solicit or collect personal information from or about children under the age of 13 without first providing direct notice to a parent or guardian and obtaining verifiable consent of such parent or guardian.

V.   For Persons Outside the United States

BitRail servers are located in the United States.  Use of BitRail services is only available to persons located in the United States.  The Site’s Personal Information practices and the terms of this Privacy Policy may or may not comply with foreign law, so if you do not agree with this, please do not use the Site or our services.

VII.   Security of Your Personal Information
As described above, we store and process your Personal Information using third party servers located in the United States. We use physical, electronic, and procedural safeguards to prevent the loss, misuse and alteration of the information under our control in compliance with applicable US federal and state laws and regulations. When you submit sensitive information via our Sites, such as bank account information, that information is subject to secure sockets layer (SSL) encryption technology.  We also exceed PCI Level 3 compliance criteria regarding the storage of Personal Financial Information, such as bank account information.  We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our offices and files and we authorize access to Personal Information only for those employees who require it to fulfill their job responsibilities.

We strive to keep our systems secure.  However, despite our efforts, no data transmission over the Internet can be guaranteed as 100% secure. As a result, while we strive to protect your Personal Information during transmission, we cannot ensure or warrant the security of any information you transmit to us or receive from us.  We urge you to take steps to keep your Personal Information safe (including your account password), log out of your account after use, and close your web browser.  If you do share your password or Personal Information with anyone, you are responsible for all actions taken in your account’s name.  If you lose control of your password, you may lose considerable control over your Personal Information and may be subject to legally binding actions taken on your behalf.  Because of this, if the security of your password has been compromised in any way, you are responsible for immediately notifying us and for changing your password.

If BitRail learns of a breach of our system security, we may attempt to notify you electronically so that you can take appropriate protective actions.  By using our services, you agree that BitRail may communicate with you electronically regarding the security of your Personal Information. BitRail may post a notice on the Site or Mobile Application if it learns a security breach has occurred.  We may also send an email to you at the email address you have provided us. Depending on where in the United States you live, you may also have a legal right to receive notice of a security breach from us in writing.

VIII.   Other Site-Related Items

1.  Your California Privacy Rights.  If you live in California and have an established business relationship with us, you can request a list of the Personal Information we have shared with third parties for their marketing purposes.  We will also give you a list of the third parties that have received your Personal Information. You can make a request one time each year. To exercise your rights, you can email us or write to us at the addresses listed in this Policy.  Mention in your letter that you are making a “California Shine the Light” inquiry. We will respond within 30 days.

2.  California “Do Not Track” Disclosures.  At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating “Do Not Track” signals. Thus, the Site is unable to respond to “Do Not Track” signals.  Please refer to the instructions in your browser in order to determine the appropriate settings in order to signal your preferences in this regard; however, be aware that all of the functionality of the Site may not be available to you if your settings block tracking cookies placed by us or by third parties. 

3.  Other Sites.  The websites of third parties may link to our sites.  We are not responsible for and have no liability for the privacy policies or practices of those websites.  We recommend that you review the privacy policies of each website you visit.

IX.   Acceptance of Privacy Policy

By using our Services, you have signified your acceptance of this Privacy Policy.  If you no longer agree with the terms of this Privacy Policy, please do not use our service or submit any Personal Information to us through our Site.

X.   Contacting Us

If you choose to visit the Site, your visit and any dispute over privacy are subject to this Privacy Policy and our User Agreement  including limitations on damages to the extent permitted by law, resolution of dispute procedures, and application of the law of the State of Georgia.  

You may review, update and modify your Registration Information by logging in and visiting Vault Settings on the Site.

If you have any concern about the privacy practices of the Site, please contact us at following address with a detailed description, and we will try to resolve it.

privacy@bitrail.io
BitRail, LLC
800 Battery Avenue SE, Suite 3090, Atlanta Georgia  30339You can Contact Customer Support  here .
XI.   Changes to Privacy Policy
We reserve the right to modify this Privacy Policy at any time, but if  we make changes to this Privacy Policy, we will post such revised policy on our Site and/or notify you by email or otherwise as required by applicable law.  If you do not agree to the changes we have made, please do not use the Site.  Your use of the Site after the effective date of any such change constitutes your acceptance of the applicable change.

Consumer Privacy Notice (Chart)

BitRail is a service provided by BitRail, LLC (“BitRail”)

FACTS: WHAT DOES BITRAIL DO WITH YOUR PERSONAL INFORMATION?

Why?     Financial companies choose how they share your personal information.  US federal law gives consumers the right to limit some but not all sharing.  Federal law also requires us to tell you how we collect, share and protect your personal information.  Please read this notice carefully to understand what we do.

What?       The types of personal information we collect and share can include:

  • Social Security number and account balances
  • Payment history or transaction history
  • Credit history or credit scores

When you are no longer our customer, we continue to share your personal Information as described in this notice.  

How?      All financial companies need to share customers’ personal information to run their everyday business.  In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons BitRail chooses to share; and whether you can limit this sharing.

Reasons we can share your Personal Information: Does BitRail share? Can you limit this sharing?
For our everyday business purposes, such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or to report to credit bureaus. Yes No
For our marketing purposes, to offer our products and services to you. Yes No
For marketing with our Joint Marketing Partners. No (We don’t share)
For our Affiliates’ everyday business purposes. No (We don’t share)
For our Affiliates to market to you. No (We don’t share)
For Non-Affiliates to market to you. No (We don’t share)

Who we are:

Who is providing this Privacy Notice?  This privacy notice is provided by BitRail, LLC, a Delaware limited liability company.

What We Do:

How Does BitRail Protect my personal information?     To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguardsand secured files and buildings.  

How does BitRail collect my personal information?     We collect your personal information, for example when you

  • Open and account or provide account information
  • Link your bank account to your BitRail account
  • Give us your contact information
  • Use your BitRail account to send or receive funds

       We also collect your personal information from others, such as credit bureaus and identity verification services.

Why can’t I limit all sharing?    Federal law gives you the right to limit only:

  • Sharing for affiliates’ everyday business purposes – information about your creditworthiness
  • Affiliates from using your information to market to you
  • Sharing for nonaffiliates to market to you

      State law and individual companies may give you additional rights to limit sharing.

      See below for more information on your rights under state law.  

Definitions

Affiliates        Companies related by common ownership or control.  They can be financial and nonfinancial companies.

Nonaffiliates     Companies not related by common ownership or control,  They can be financial and nonfinancial Companies.

  • Nonaffiliates with which we share personal information include service providers that perform services or functions on our behalf.

Joint Marketing      A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • We do not have any joint marketing partners

Other important information

We may transfer personal information to other countries to process transactions or for customer service.  

California: If your BitRail account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law.

Vermont: If your BitRail account has a Vermont mailing address, we will not share personal information we collect about you with non-affiliates unless the law allows or you provide authorization.  

Effective Date:  January 11, 2019