Privacy Policy

1. Introduction

The main purpose of this document is to provide you with information about the processing of personal data carried out by Libertify (“Liberty” or “we”) in a concise, transparent, intelligible and easily accessible form, to help you understand how your data are processed.

2. Data are collected fairly and in a transparent manner

In order to ensure fair and transparent data collection, we provide information on each processing operation we carry out by means of information notices.

Data are collected fairly. No data is collected without the knowledge or information of the data subjects.

3. Data are collected for legitimate and proportionate purposes

When we process data, we do so for specific purposes: each data processing carried out by us has a legitimate, specified and explicit purpose.

For each of the processing carried out, we undertake to collect and use only data that are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

We ensure that the data are kept up to date and take steps to ensure that data that are inaccurate are erased or rectified.

4. What data do we process?

In the context of the processing of personal data, the purposes of which are presented to you below, we collect and process the following categories of data:

Identification data of data subjects;

Data on the use of the services offered on the Libertify platform;
Data necessary for the management of the contract;
Your exchanges with Libertify;

You will be informed whether the data to be provided are mandatory or optional at the time of their collection. If you refuse to provide mandatory data, Libertify will not be able to provide you with the Services (such as the creation of your user account, access to the platform’s functionalities or the processing of your order).

If you provide us with the personal data of a third party, we remind you that you are required to inform that person of the disclosure and processing of their personal data by Libertify and to communicate this policy to them.

Users of the www.cryptoseatbelt.com site and the Libertify platform may be associated, by the devices, applications, tools and protocols they use, with online identifiers such as IP addresses, cookies or other connection identifiers. These identifiers may leave traces which, especially when combined with unique identifiers and other information received by the servers, may be used to create profiles of individuals and identify them. For more information on the cookies used by Libertify, please read our Cookie Policy.

5. What are the purposes and legal bases of our processing?

The processing operations carried out by Libertify have the following purposes and legal bases:

Purpose	Legal Bases
Ensuring the operation of the platform and the provision of servicesto users, in particular the establishment of a risk profile	Performance of the contract
Improving the quality and operation of the services	Legitimate interests
Managing contracts (managing and tracking orders, payments)	Performance of the contract
Keeping general accounting	Compliance with a legal obligation relating to a data storage requirement
Establishing financial statistics concerning customers	Legitimate interests
Monitoring customer relationship for complaint management	Performance if the contract
Managing prospects (notification of the launch of the platform)(2)	Consent
Managing requests from competent authorities or courts (communication of requested data)	Compliance with a legal obligation
Managing pre-litigation or litigation relating to the contract or not	Libertify’s legitimate interest in establishing proof of a right or contract(3)

2. Note: we have noticed on the current version of the “https://cryptoseatbelt.com/” website the possibility for a user to enter their email address in order to be alerted of the launch of the platform. We therefore propose to keep this purpose, in the event that the privacy policy is posted online before the launch of the platform. Furthermore, as registering to this alert constitutes a form to collect personal data (the email address), we recommend adding the following essential information, in accordance with the CNIL’s recommendations: the identity of the controller, the purposes of the processing, the list of and method for exercising the rights of data subjects, and a reference to the privacy policy.

3. In this case, Libertify must carry out a balancing test which aims to ensure that Libertify’s legitimate interest would not infringe the fundamental rights and freedoms of the data subjects. In its Opinion No. 06/2014, the WP29 proposes to balance the interests of the controller against the fundamental rights and freedoms of the data subjects. In doing so, several elements should be taken into account, such as:

the nature of the interests of the controller;
the impact of the processing on the data subjects;
the nature of the data (sensitive data in a strict or broader sense);
the status of the data subject (minor, employee, etc.) and of the controller (e.g. whether a business organisation is in a dominant market position);
the way data are processed (large scale, data combination, profiling, disclosure to large number of people or publication);
data subjects’ reasonable expectations;
the impact of the processing.

This balancing test must be documented so that it can, if necessary, be reproduced in response to any request that the CNIL may make.