Политика конфиденциальности

Draft for legal review. This is a working example and has not been approved. Items in [brackets] need confirming.

Last updated: [date]

1. Controller

LLC Coinbit (ОсОО «КоинБит»), [registered address], processes your personal data in line with the Digital Code of the Kyrgyz Republic and related regulations. Data protection contact: [name / email].

2. Data we collect

• Contact data: name, email, phone, company name.
• Identification data: identity documents, date of birth, address, and for companies, details of directors and beneficial owners.
• Transaction data: orders, amounts, wallet addresses, bank account details.
• Technical data: IP address, browser details, and the cookies described in our Cookie Policy.

3. Why we use it and our legal grounds

• To perform our agreement with you: quoting, executing and settling trades.
• To meet legal duties: client identification, transaction monitoring, record-keeping and reporting.
• With your consent, for specific purposes we tell you about, such as marketing. You can withdraw consent at any time.
• [Other lawful grounds confirmed under the Digital Code.]

4. Who receives your data

• Regulators and the financial intelligence authority of the Kyrgyz Republic, when the law requires.
• Service providers acting for us: identity verification, blockchain analytics, hosting, email. [List of processors.]
• Banks and counterparties, as needed to settle your trade.

5. Transfers outside the Kyrgyz Republic

Where data is sent abroad, we do so only as the law allows, and where required, with your explicit consent. [Confirm the position on adequacy and data localisation.]

6. How long we keep it

We keep identification and transaction records for at least five years after the relationship or transaction ends, or longer if the law requires. Other data is kept only as long as needed for its purpose.

7. Your rights

You may ask to access, correct or delete your data, object to certain processing, and withdraw consent, subject to our legal retention duties. Write to [email]. You may also complain to the authorised personal data protection body of the Kyrgyz Republic.

8. Security

We use technical and organisational safeguards appropriate to the sensitivity of the data, including access control and encryption in transit.

9. Changes

We will publish any update to this policy on this page.