The information here in is given in compliance with article 13 of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation or GDPR) to individuals interested in receiving news, information, invitations, publications, announcements and newsletters relating to the activities conducted by RBB S.r.l.
“Personal data” (article 4, paragraph 1 of the GDPR) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Special categories of personal data” (article 9, paragraph 1 of the GDPR) means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
“Processing" (article 4, paragraph 2 of the GDPR) means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
For the purposes of the GDPR (article 24) the Data Controller is:
RBB S.r.l., Piazza Enriquez, 22/C, 47891 Dogana, Repubblica di San Marino
Type of data processed
As part of our activities, we collect and use personal data provided by you, the data subject. We might collect the following types of personal data in connection with the activities described below: your name, e-mail address, country, origin of the funds and wallet address.
Purpose of processing
We might collect and use personal data for the following purposes:
- Registering for an account or filling in forms on our websites;
- Completing a profile or uploading documents from our website;
- Interacting with us on social media, such as by tagging us and/or our products, or permitting us to follow your social media profile;
- Purchasing our products and services from us;
- Participating in or registering for events, consumer contests and other promotions;
- Using other features of our websites that may be offered from time to time, which may require such information in order to utilise the feature;
- To gather feedbacks from your profile for our legitimate interest in better understanding user expectations and improving our website;
- To provide products and services to you, which includes processing payments, sending notifications related to your purchases, and processing exchanges;
- To respond to any communications from you or communicate with you about our initiates, marketing or events;
- To measure your social media engagement with our Company (the legal basis for this processing is our legitimate interest in understanding the efficacy of our marketing strategies);
- To detect, investigate and prevent fraudulent transactions, error, negligence, breach of contract, and other illegal activities and protect against harm to the rights, property or safety of RBB S.r.l. and our users, customers, employees or the public, including by using video surveillance systems (the legal basis for this processing is our legitimate interest in preventing fraud, error, negligence, contractual breach and other illegal activities and protecting and securing our premises, customers, employees and the public);
- To comply with our legal obligations, including our tax obligations, those related to the prevention of fraud and money laundering, and those required for you to benefit from rights recognized by law, or any regulatory requirements or provisions (the legal basis for this processing is compliance with our legal obligations under laws in the EEA related to, for instance, taxation, money-laundering and terrorism financing and consumer protection law).
Disclosure of Personal Data
We do not share personal data about you with third parties, except as follows:
- a) Professional Advisors. We share personal data with our legal, financial and other advisors in connection with the kinds of corporate transactions described above or in connection with the management of all or part of RBB S.r.l.’s business or operations.
- b) Compliance with Law. We disclose personal data when we believe doing so is reasonably necessary to comply with applicable law or legal process (including requests from authorities), to respond to claims (including inquiries by you in connection with your purchases from RBB S.r.l.), or to protect the rights, property or personal safety of RBB S.r.l., our users, employees or the public.
We don’t transfer your data outside the EEA.
Third Party Sites
Please note that our website and platform contain links to third-party websites that are not controlled or operated by RBB S.r.l. We need them in order to permit you to comply a positive KYC. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that RBB S.r.l. does not accept any responsibility or liability for these policies, even if RBB S.r.l. paid a lot of attention during the selection of the its partners. We suggest that you review these policies before you disclose any personal data when visiting such third-party websites.
Legal basis for processing personal data
For the purposes set out above, the legal basis of processing is the consent you, the data subject, give to the processing of your personal data, as per art. 6, let. a), b) c) GDPR.
Data Subject Rights
In relation to your personal data you can exercise your rights as data subject under the GDPR https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679, namely:
- Right of access [article 15 of the GDPR];
- Right to rectification [article 16 of the GDPR];
- Right to erasure (‘right to be forgotten’) [article 17 of the GDPR];
- Right to restriction of processing [article 18 of the GDPR];
- Right to data portability [article 20 of the GDPR];
- Right to object [article 21 of the GDPR].
You have the right to withdraw your consent at any time.
The rights set out above can be exercised in writing by sending an email to firstname.lastname@example.org
Pursuant to article 19 of the GDPR, we shall communicate any rectification or erasure of personal data or restriction of processing requested by you, the data subject, to each recipient to whom your personal data has been disclosed, unless this proves impossible. You as data subject have also the right to lodge a complaint with the San Marino Data Protection Authority, Via Scala Bonetti, 2 - 47890 San Marino - Repubblica di San Marino.
For further information about data subjects rights visit our website.
We retain personal data only for as long as necessary to achieve the purpose for which such personal data was collected, unless a different retention period is required under applicable law. We also retain personal data for as long as you have your account, or as long as is needed to be able to provide the services or products to you. If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, RBB S.r.l. may also keep personal data as required, after an account is closed or is no longer necessary to provide services. Unless otherwise required by applicable law, RBB S.r.l. will take reasonable steps to destroy or permanently de-identify personal data it holds if such personal data is no longer needed for the purpose for which it was collected.
Consent to data processing
You are free to give or withhold your consent to processing of your personal data for the purposes above. We need your freely given consent to send you communications, information, invitations, publications, announcements and newsletters regarding our company. Should you deny your consent, we will be unable to send you said communications.
We also process your data on different legal basis, that don’t need consent, in order to execute our contract with you or comply with authorities’ requests, as stated above.
How data is processed
We process your personal data on paper or electronic form and enter your data into relevant databases that may be accessed – hence your data be disclosed to – our Company’s employees, contractors/consultants interns and other authorized individuals. Said employees, contractors/consultants interns and other authorized individuals may consult, use, process, compare the data as well as carry out any other appropriate action, including using automated means, always in compliance with statutory requirements that ensure, inter alia, protection of the confidentiality and security of the personal data, as well as data accuracy, update and appropriateness to the purposes for which the data is collected and used, as stated above.
Changes and updates
The Data Controller may make changes and/or additions to this privacy notice including as a result of regulatory changes.