Privacy Policy

We are committed to protecting your personal data and your privacy.

This privacy policy has been drafted to inform you how we manage, collect, store and use the information you provide to us in connection with our website Shift Kinrix Opt (the "Website").

We respect the following principles:

• We remain transparent regarding the collection and processing of personal data relating to you.

It is important that you always have all the necessary information so that you can make an informed decision about the processing of your personal data. To do this, we use various techniques and means designed to provide you with relevant information about the processing of your personal data in an appropriate manner and at an appropriate time.

Also, where we determine that it is necessary to provide certain information, we will do so at an appropriate time and place.

Also, subject to legal restrictions, please feel free to contact us if you have any questions. To do so, please email us at the following address: 

• We only handle your personal data for the purposes indicated in this policy.

The purposes for which we process your personal data include, among others, enabling you to use our website and providing the services contained therein (the "Services"), improving user experience on our website, improving our services, protecting our rights and interests, carrying out commercial and administrative activities that support the provision of our services to users, and/or complying with legal and/or regulatory requirements.

Furthermore, we process your personal data in order to understand your personal needs and preferences.

• We invest significant resources to respect your rights relating to personal data concerning you:

• • We apply significant resources so that you can exercise your rights as a data subject. Therefore, you may contact us at any time to review your personal data, modify it, delete it, suspend its use for specific or general purposes, or transfer it to you or to a third party. We will carry out your wishes in accordance with the law.

• Protection of personal data relating to you:

Although we cannot promise absolute protection of your personal data, we are committed to using, and will continue to use, a wide range of measures and means aimed at ensuring the security of your personal data.

Our full privacy policy.

1. What is the scope?

This policy describes the types of personal data we collect regarding natural persons, as well as how we collect, use, share with third parties, protect, process and otherwise handle it.

In this policy, "personal data" refers to information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly, or in combination with additional information that we hold or to which we have access.

In this policy, "processing" of personal data refers to any operation or set of operations performed on personal data, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission , dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.

Our services are intended for the general public and are not aimed at children under the age of 18. We do not knowingly collect or solicit information from persons under 18 years of age, nor do we knowingly permit such persons to access our services. If we become aware that information relating to a child has been collected, we will take reasonable steps to delete such information as soon as possible.

2. When do we collect your personal data?

We collect your personal data every time you use our services, use our service channels, use the website and/or contact us. Sometimes you actively provide us with personal data yourself, and sometimes we collect personal data about you by studying and analyzing the use of our services and/or our service channels.

3. You have no obligation to provide the company with personal data, and the effect of doing so

You are not obliged to provide us with your own personal data. However, in some cases, failure to provide such personal data may mean that we are unable to provide you with a service, that you are unable to use the website, or that our services and website malfunction.

4. What personal data do we collect about you?

Personal data is collected by us every time you browse the website. This information includes online activity logs, traffic information (such as IP address, access time and access date), the language you use, software crash reports, the type of browser you use, and information about the device you used. Some of this information may not constitute personal data, as it may not identify an individual.

Personal data we receive from you: personal data you provide to us of your own free will when you contact us.

Personal data you specifically provide for transmission to a third party: this information includes your name and email address.

5. Purposes of processing personal data and their legal basis

We process your personal data in accordance with an appropriate legal basis, for one or more of the purposes set out in this section.

We do not process your personal data unless there is a legal basis for such processing. The legal bases on which we process your personal data are as follows:

1. You have consented to the processing of your personal data for one or more specific purposes. This refers to instances where you specifically provide your data through the website for presentation to a third party.
2. The processing is necessary for the legitimate interests pursued by us or by a third party.. For example, in order to improve our services, or for the exercise or defense of legal claims.
3. This processing is necessary in order for us to fulfil a legal obligation to which we are subject..

You may contact us at any time by sending a notice to the email address , in order to receive information about the reviews we have carried out. This is so that you can conclude that we may process your personal data because such processing is necessary for legitimate interests pursued by us or by a third party.

The list below describes the purposes for which we process personal data relating to you, as well as the legal basis for such processing.

6. Transfer of personal data to third parties

We may also share your personal data with third parties that provide services such as hosting and storage providers, IP address information, user experience analysis, research, analysis, and technical and diagnostic services.

Furthermore, you may specifically request that we submit certain personal data relating to you to a third-party bitcoin trading platform. In such cases, we will share the personal data you provide to us for this purpose with such a third party, and their use of your personal data will be subject to their own privacy policies.

We may also share personal data relating to you with related entities and business partners. These entities provide us with resources to enhance and improve the level of services and products we provide to users.

We may share personal data relating to you with governmental, local, public and regulatory authorities, as well as where such disclosure is necessary to protect our interests, rights, assets and the interests of third parties, including the initiation, exercise or defense of legal claims .

Furthermore, to potential purchasers or investors in, or lenders to, the company and/or companies of the group of companies to which the company belongs, or in the case of similar transactions (sale of the company's assets and/or those of the group of companies to which the company belongs), and/or in connection with a merger, reorganization, consolidation or bankruptcy of the company and/or of the companies of the group of companies of which the company is a part.

7. Cookies and third-party services

We may use certain third-party services that may use cookies and other technologies, such as analytics companies and companies that serve advertisements on our website, and their practices and providers are subject to their own policies.

Cookies (small text files) are installed on the device you use to visit or access the website. Cookies allow information about you and your behavior to be collected in order to improve user experience, remember your preferences and settings, and personalize and offer products and services that may be of interest to you. Cookies may also be used to collect statistics and carry out analyses.

Some of the cookies we may use are session cookies, which are temporarily downloaded to the device and last until you close the web browser, while others are persistent cookies, which remain on the device after you stop browsing, in order to help the website remember you as a returning visitor when you visit it again.

Types of cookies:

The cookies we may use are classified according to their function as follows: 

Blocking and removing cookies

You can change your browser settings to block and remove some or all cookies. For information on how to do this in some of the more popular web browsers, please see the following links.

• Firefox
• Internet Explorer
• Google Chrome
• Safari

Please note, however, that in such a case, some or all of the website may not function as intended.

Online tracking notice

At this time, this service does not permit "do not track" signals.

8. Retention of personal data

We retain your personal data for as long as necessary to achieve the purposes of processing personal data set out in this policy, or for a longer period as required by the laws, regulations, policies and orders applicable to us.

To ensure that your personal data is not kept longer than necessary, we regularly review the personal data we hold and investigate whether it can be erased.

9. Transfer of personal data to third countries or international organizations

Personal data relating to you may be transferred to a third country (that is, a jurisdiction other than your place of residence) or to an international organization. In such circumstances, the company employs appropriate security measures to guarantee the protection of your personal data and to ensure that interested parties can exercise their rights and obtain effective legal remedies.

If you are a resident of the EEA (European Economic Area), please note that these safeguards and protections will be available if one of the following conditions is met.

• The transfer is a transfer to a third country or international organization which the European Commission has decided offers an adequate level of protection for the personal data transferred, pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR"), including transfers pursuant to the EU-US Privacy Shield framework.
• The transfer is pursuant to a legally binding and enforceable instrument between public authorities or bodies, pursuant to Article 46, section 2, letter a) of the GDPR. Or
• The transfer complies with the standard data protection clauses adopted by the European Commission, pursuant to Article 46, section 2, letter c) of the GDPR. The clauses adopted by the European Commission can be found at the following URL:&nbsp;<a href="https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en">https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en</a>.&nbsp;
• You may request that we provide details of the safeguards we use to protect your personal data transferred to a third party or international organization, by sending an email to the following address:  

10. Protection of personal data

We apply appropriate technical and organizational measures to guarantee an appropriate level of security for personal data, taking into account in particular the risks presented by processing, such as accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Due to legal or other obligations outside of our control, we may sometimes be required to transfer personal data relating to you to third parties, such as public authorities. In such circumstances, we exercise limited control over the level of protection given to personal data relating to you by such third parties.

The transmission of personal data via the internet is not completely secure. Therefore, we cannot guarantee the protection of your personal data when it is transmitted to us over the internet.

11. Links to third-party websites

The website may provide links to third-party websites and/or applications. We do not control such websites and applications, nor the collection and/or processing of your personal data by such websites and applications, and we are not responsible for such websites and applications, or for their privacy and data protection policies and practices. This policy does not apply to actions carried out through such websites and/or applications.

Whenever you access such third-party websites and/or applications, we recommend that you carefully review their privacy policies before using such websites and/or applications, and before disclosing any personal data relating to yourself.

12. Changes to this policy

We may amend the terms of this policy from time to time. Whenever we amend this policy, we will notify you of such changes by posting the updated policy on the website. Furthermore, if we make significant changes to this policy, we will endeavor to notify you of such changes through communication means that we consider reasonably appropriate to notify such changes, as well as by posting notice of such changes on the website. Unless otherwise stated, all changes become effective upon the updated policy being posted on our website.

13. Your rights regarding personal data relating to you

In general, you have the right to request confirmation as to whether we are collecting your personal data, to request confirmation of such data, to correct its content as necessary, and to delete personal data that is no longer necessary. You may also restrict your consent to specific processing of personal data.

If you are a resident of the EEA, please read the following section.

You have the following rights with respect to personal data relating to you. To exercise these rights, you may send a request to exercise your rights to the following email address: 

Right of access

You have the right to obtain from the company confirmation as to whether or not personal data relating to you is being processed, and, where that is the case, access to the personal data and the following information: (1) the purposes of the processing; (2) the categories of personal data concerned; (3) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organizations; (4) where possible, the envisaged period for which the personal data will be retained, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from us rectification or erasure of personal data, or restriction of processing of personal data concerning you, or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) available information as to the source, where the personal data are not collected from you; (8) the existence of profiling; (9) where personal data are transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer.

The company will provide you with a copy of the personal data undergoing processing, and may charge a reasonable fee for any further copies you request. Where you make a request electronically, the information will be provided in a commonly used electronic format, unless you specifically request otherwise.

The right to obtain a copy of personal data must not adversely affect the rights and freedoms of others. Accordingly, where a request would adversely affect the rights and freedoms of others, we may not respond to your request, or may respond in a limited manner.&nbsp;

Right to rectification

You have the right to obtain from the company the rectification of inaccurate personal data relating to you. Taking into account the purposes of the processing, you have the right to have incomplete personal data relating to you completed, including by means of providing a supplementary statement.

Right to erasure

You have the right to obtain from us the erasure of personal data relating to you where one of the following grounds applies: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) you withdraw the consent on which the processing is based, and there is no other legal ground for the processing; (c) you object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on legitimate interests pursued by us or by a third party, and there are no compelling legitimate grounds for the processing; (d) you object to the processing of personal data relating to you for direct marketing purposes; (e) the personal data have been unlawfully processed; or (f) the personal data relating to you must be erased for compliance with a legal obligation under European Union law or the law of the member state to which we are subject.

This right does not apply to the extent that processing is necessary: (a) for compliance with a legal obligation which requires processing under European Union law or the law of the member state to which we are subject; or (b) for the establishment, exercise or defense of legal claims.

Right to restriction of processing

You have the right to obtain from us restriction of the processing of your personal data where one of the following situations applies: (a) you contest the accuracy of the personal data relating to you, for a period enabling us to verify the accuracy of the personal data relating to you; (b) the processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead; (c) we no longer need your personal data for the purposes of processing, but you require it for the establishment, exercise or defense of legal claims; (d) you have objected to processing of your personal data pursuant to legitimate interests pursued by us or by a third party, pending verification as to whether our legitimate grounds override yours, or for the establishment, exercise or defense of legal claims; or (e) your personal data is processed for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.

Where processing of your personal data has been restricted as a result of your request, such personal data shall, with the exception of storage, only be processed with your consent, or for the establishment, exercise or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or of a member state.

Right to data portability

You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, and to have the right to transmit that personal data to another data controller where: (a) the processing is based on your consent or on a contract to which you are a party, and (b) the processing is carried out by automated means.

In exercising your right to data portability, whenever technically feasible, you have the right to have your personal data transmitted directly from the company to another data controller. The exercise of your right to data portability is to be understood without prejudice to your right of erasure and the rights of the company. Furthermore, the right to data portability must not adversely affect the rights and freedoms of others.

Right to object

You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data based on legitimate interests pursued by us or by a third party, including profiling based on those legitimate interests. In this case, we will stop processing your personal data, unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

You have the right to object at any time to the processing of personal data for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.

Right to withdraw consent

Any consent you have given us for the processing of personal data may be withdrawn at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority established by a member state, for the protection of the fundamental rights and freedoms of natural persons in relation to the processing of personal data in the European Union.

As set out in this Section 13, your rights regarding personal data relating to you may be limited by European Union law or the law of the member state to which we are subject.

We will provide the information requested pursuant to your rights set out in this Section 13 without undue delay, and in any event within one month of receipt of the request. That period may be extended by a further two months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

Information requested pursuant to your rights set out in this Section 13 shall be provided free of charge, unless otherwise stated in this Section 13. Taking into account the administrative costs of providing the information or communication, or of taking the requested action, we may either charge a reasonable fee, or (b) refuse to act on the request.

Where there is reasonable doubt as to the identity of the natural person making the request, the company may request the provision of additional information necessary to confirm your identity in order to fulfil the request in accordance with your rights set out in this Section 13.