(Last Updated: April 2024)

This Privacy Policy ("Privacy Policy" or "Policy") outlines what Personal Information is collected by Ballerine Inc. (“Ballerine”, “we”, “us” or “our”), how we use such Personal Information, the choices you have with respect to such Personal Information, and other important information. This Privacy Policy applies whenever you use or interact with our website https://www.ballerine.com (the "Website"), Ballerine Web Platform and Ballerine Web Application (the "Platforms"), Ballerine API or any other site, mobile application or service we provide, and any content or material provided thereon (collectively, the "Services").

If you do not agree to this Policy, please avoid using our Services. You are not legally required to provide us with any Personal Information, but without it we will not be able to provide you with the best experience.

FROM WHOM DO WE COLLECT PERSONAL INFORMATION

This Privacy Policy applies to Ballerine's collection, use, and disclosure of the Personal Information of the following categories of individuals:

Website Visitors: Individuals who visit our Website and who may volunteer Personal Information.

Customers: Those who sign up to our Services or engage with us with respect thereto.

End Users: Individuals who undergo Know Your Client (KYC) or Know Your Business (KYB) processes by our Customers.

TYPES OF DATA COLLECTED AND PURPOSES

Depending on your interaction with us, we may collect two types of data from you:

“Non-Personal Information”** means aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Service. We are not aware of the identity of the user from which the Non-Personal Information is collected. Such Non-Personal Information may include aggregated usage information and technical information transmitted by your device, such as browser version, operating system type and version, mobile network information, device settings, and software data.

"Personal Information" or "Personal Data" means ****individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (including “Personal Data” as defined under the GDPR).

For the avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

The table below details the types of Personal Information we collect, the methods and purpose of such collection, and our lawful basis for processing such Personal Information:

INFORMATION TYPE METHODS AND PURPOSE LAWFUL BASIS
KYC/KYB Information
Ballerine collects and further processes End Users' Personal Information on behalf of its Customers, to provide it with the KYC/KYB results, including name, date of birth, address, identification number and government-issued ID(s) (in KYB procedure, this Personal Information pertains to the managers and the owners of the business) ("KYC/KYB Information"). We receive KYC/KYB Information by our Customers for the purpose of identifying and verifying our Customer's End Users as part of our Customer's KYC/KYB process. We process KYC/KYB Information subject to (a) your consent (which was provided to our Customers) and (b) fulfilling our contractual obligation towards our Customers.
Further processing may be subject to our legitimate interest, for example for complying with financial regulations, management
Security, fraud prevention and improvement of our Services purposes.
Contact Information
If you voluntarily contact us, through any means of communications we make available on our Website (for example, the “Book a Demo” page), for support or other general inquiries you will be required to provide us with certain information such as your name, email address, and any additional information you decide to share with us (“Contact Information”). We process Contact Information and Account Information to provide our Services, to open an Account in our Platforms, to respond to your inquiries, and provide you with the support, materials and information you have requested. We process Contact Information and Account Information subject to (a) your consent and (b) fulfilling our contractual obligation towards our Customers. Further processing may be subject to our legitimate interest, for example for internal documentation and improvement of our Services purposes.
Account Information
When you register an account with our Services, you will be required to do so using your name, e-mail address, etc. ("Account Information").
Services Interaction and Marketing
When you interact with our Services, we may collect your online identifiers, such as Internet Protocol (IP) address and Cookie ID (“Online Identifiers”). We collect Online Identifiers to operate the Services and enable its proper functionality, to analyze usage on our Service, improve our user experience and safety, and display relevant content. Such collection is based on (a) consent (where applicable, namely in the EU, where such data is collected through the use of Tracking Technologies, as mentioned below); (b) our legitimate interests, which in this case are operating and promoting our Services, and providing the best user experience.
Legal Matters We may use certain Personal Information to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Services, to enforce our legal terms and conditions, to protect the security or integrity of our databases, and to take precautions against legal liability. Such processing is based on our legitimate interests, which in this case are protecting our Services and data, exercising our legal rights, and complying with our legal obligations.