Last update: May 24, 2018
3commas team (the “3commas” ) manages online software as a service including website http(s)://3commas.io, mobile applications, application program interfaces, social media platforms, all together or each separately are referred to as the “Software” ), and provides add-ons, built-in services and technical support.
3commas team team is represented by Trendlux OÜ – a limited liability company incorporated under the laws of the Republic of Estonia with registration code 14125515 and registered office at Laki tn 30, Tallinn, 12915, Estonia. 3commas is also referred to as “we” (“us”, “our”). p “Users” in definition of the Terms are individual private person(s) or legal entity making use of the Software. Users are also referred to as “you” (“your”).
For the purpose of the relevant data protection regulations, 3commas is the data controller of your information. We respect all personal information (including individually recognizable corporate email addresses) and also understand that occasionally, some individuals, sole traders and partnerships may also use our products and services. Therefore the provisions, measures and rights in this privacy notice are applied to all forms of data collected on our site and through our company. 3commas processes your personal information to meet our legal and statutory obligations to provide our Users with our Software.
2. Information That We Collect
The list of personal information that we may process and collect from you:
a. email address;
b. name and family name;
c. phone number (landline or cellular), including any phone number used to call our support number;
d. device identifiers (network and hardware): IP address, Mobile device ID;
e. software identifiers and information (operating system and browser): platform, version, headers, plugins, geographical location, time zone setting, cookies;
f. information in profiles of third party products and services (messengers, social networks, cryptocurrency exchanges, wallets etc.), if provide us such data or use such products and services on your own initiative.
Also, if we are forced to comply with a request or requirements of the competent authorities, and/or we have reason to suppose that invalid or suspicious activity is made under your account, we can reasonable ask you to provide:
a. documents proving your identity (Passport, ID card etc.);
b. documents certifying your address of residence (utility bill, bank account statement etc.);
c. photo or video conference with you personally and identity document;
d. documents on the financial transaction.
We will collect information from you if you:
b. register an account and logging in the Software;
c. have got an account on third party service (exchanges, wallets etc.) and add API keys for this service to the Software;
d. contact us via email, messenger, social network, online contact form in the Software;
e. make a payment for license and/or service fee for the Software.
3. Uses made of the information
The purposes and reasons for processing your personal information are detailed below:
a. to carry out our obligations relating to your contract with us to provide you with the Software;
b. to keep our Software-based services safe and secure;
c. to answer your queries and notify you about changes;
d. as part of our legal obligation for business accounting and tax purposes;
e. to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;
f. to administer our internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
We may receive information about you if you use any of websites we operate or any of services we provide.
4. Legal Basis for Processing
We take your privacy issues very seriously and will never disclose, share or sell your information without your consent, unless required to do so by law or court. p The Software and all associated services are all directed to people who are at least 18 years old. We do not collect any information from anyone under 18 years of age.
When registering with the Software you are signing up to our marketing or mailing list and will contact you occasionally via email and messengers for promoting our products and services. Processing for any purpose other than those specified in this policy are only done with your consent, which you are free to withdraw at any time.
5. Your Rights
You have the right to be granted an access to personal information that 3commas holds or processes about you and to request information about:
a. what personal information we hold;
b. the purposes of processing of personal information;
c. the categories of personal information concerned;
d. the recipients to whom the personal information has/will be disclosed;
e. how long we intend to store your personal information for;
f. if we did not collect the information directly from you, information about the source
If you believe that we hold any incomplete or inaccurate information about you, you have the right to ask us to correct or complete the information, and we will strive to update/correct it within a reasonable time, unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal information or to restrict its processing in accordance with the data protection law, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use.
If we receive a request for any of the above rights, we may ask you to verify your identity before acting on the relevant request to be ensured your information is protected and kept secure. In any case you are able to modify and update some of your personal information by logging into your account of the Software.
6. Sharing and Disclosing Your Personal Information
We do not share or disclosure any of your personal information without your consent, other than for the purposes specified in this notice, where there is a legal requirement or to enforce our terms and conditions.We may share your information with selected third parties including:
a. affiliates, business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you;
b. advertisers and advertising networks solely to select and serve relevant adverts to you and others;
c. analytics and search engine providers that assist us in the improvement and optimisation of our website;
d. our group entities or subsidiaries.
We use several payment services providers (PSPs) to process the transactions on website and mobile applications of the Software. Any sensitive payment information is processed directly by their servers, meaning that we do not store any sensitive payment details. By starting the payment process for an order, you shall agree to your information being processed by the above PSPs. All payment functions are carried out on the PSP’s secure site, which is to their own terms and conditions.
We use several social media networks and messengers for communicating and support. If you link your social media account we will receive relevant information that is necessary to enable Software-based services and request the access to the contacts in your social media account, so that you can recommend our Software to your family and friends.
The Software may contain links to and from third party websites. By following these links please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.
7. The location of Personal Information processing and storage
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. We ensure that both ourselves and our partners take adequate and appropriate technical, physical and organisational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.
8. Automated Decision Making
As part of being a highly technical and innovative company 3commas may use Automated Decision Making (ADM) in order to improve your experience or to comply anti-money laundering obligations under applicable law. None of our ADM processes have a legal effect on you.
9. Safeguarding Measures
Although we will do our best to protect your personal data, we cannot guarantee the security of your data during transmission, and any transmission is at your own risk. Once we have received your information, we will use security features and takes every reasonable measure to try to secure your personal information and prevent unauthorised access, alteration, disclosure or destruction.
10. Consequences of Not Providing Your Information
You are not obligated to provide your personal information to 3commas, however, as it is required so that we can process your order(s) and meet our business obligations, we will be unable to provide you with the Software without it.
11. How Long We Keep Your Data
3commas only ever retains personal information for as long as you use our Software. You can unsubscribe and close your account on website at anytime.
We use the following cookies:
a. strictly necessary cookies, that are required for secure operating of the User's account in the Software allowing among other things the logging in option.
b. performance cookies, that are required for load balancing by means of recognising and counting the number of active users of the Software.
c. functionality cookies, that help us to personalise content and store your preferences allowing automatic choice of language and region.
d. targeting cookies, that help us to relevant to your interests by recording the pages you have visited and the links you have followed. We may use this information to make the advertising displayed on website.
Please note, that third parties, including, but not limited to advertising networks, payment service providers, web traffic analysis services may also use mainly performance or targeting cookies, over which we have no control.
We only retain your information for as long as is necessary and for the purposes specified in this notice. Except for cookies that are necessary, performance or functionality, all other cookies will expire after 10 years.
13. Complaints, comments and suggestions
Laki tn 30, Tallinn, 12915, Estonia
Registration code 14125515 in the Commercial Register of companies of the Republic of Estonia
VAT number EE101951896