IDENTITY OF THE DATA CONTROLLER

The administrator of your personal data is Fujara Networks s.r.o., with its registered office at Vajnorská 100/B, Bratislava – mestská časť Nové Mesto 831 04,
, ID No.: 56 366 451, VAT No.: 2122294636.

We process data in accordance with applicable European Union and local law, in particular:

• Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR),
• regulations concerning the protection of personal data,
• anti-money laundering and counter-terrorist financing (AML/CTF) regulations,
• and, where applicable, Regulation (EU) 2023/1114 (MiCA).

ADMINISTRATOR CONTACT DETAILS

For matters relating to the processing of personal data, please contact us using the form available at:
Bitcoin ATM.com/contact

PURPOSES AND LEGAL BASIS FOR PROCESSING

We process your personal data for the following purposes:

• provision and handling of services (identity verification, transaction execution, handling of requests) – Article 6(1)(f) of the GDPR,
• fulfillment of legal obligations, including tax, accounting, and AML/CTF obligations – Article 6(1)(c) of the GDPR,
• Establishing, investigating or defending against claims - Article 6(1)(f) RODO,
• processing based on consent – Article 6(1)(a) of the GDPR,
• identity verification and fraud risk assessment – Article 6(1)(c) and (f) of the GDPR,
• To ensure the security of the systems - Article 6(1)(f) RODO,
• processing of biometric data (e.g., facial image) – based on explicit consent (Article 9(2)(a) of the GDPR).

SHARING OF PERSONAL DATA

Your data may be shared:

• IT, hosting, and cloud service providers,
• communication providers (SMS, notification systems),
• legal advisors, accountants and auditors,
• Data archiving and destruction entities,
• public and supervisory authorities – only to the extent required by law.

Entities processing data on our behalf are required to maintain confidentiality and comply with the GDPR.

TRANSFER OF DATA OUTSIDE THE EOG

Data may be transferred outside the European Economic Area (EEA) only on the basis:

• European Commission decision on the adequate level of protection,
• standard contract clauses (SCCs),
• binding corporate rules (BCRs).

Before transferring data, we conduct a TIA and apply security measures such as encryption and pseudonymization.

CATEGORIES OF DATA PROCESSED

We process, among other things:

• identification data (first name, last name, address, identity document),
• contact details (phone number, mailing address, email address if provided),
• KYC/AML data (face image, PEP status, source of funds),
• biometric data – only with consent,
• transaction data (wallet addresses, transaction history),
• technical data (IP, device identifiers, system logs),
• communication data (forms and correspondence sent via Bitcoin ATM.com/contact),
• consent data,
• CCTV monitoring data (for security purposes).

DATA RETENTION PERIOD

• service data: for the duration of service provision + up to 6 years,
• data required by law (AML/taxes): at least 5 years,
• data required for claims: up to 6 years,
• data processed on the basis of consent: until consent is withdrawn,
• monitoring: up to 72 hours (or longer if required by the authorities),
• system logs: up to 90 days.

After these periods, the data is deleted or anonymized.

YOUR RIGHTS

You have the right to:

• access to data,
• corrections,
• deletion ("right to be forgotten"),
• processing restrictions,
• data portability,
• Object to processing,
• withdrawal of consent.

To exercise your rights, please use the form:
Bitcoin ATM.com/contact

RIGHT OF COMPLAINT

You have the right to lodge a complaint with:

President of the Office for Personal Data Protection
ul. Stawki 2, 00-193 Warsaw
📞 +48 22 531 03 00
✉️ [email protected]
🌐 www.uodo.gov.pl

VOLUNTARY PROVISION OF DATA

Providing data is voluntary, but in some cases mandatory (e.g., KYC, legal requirements).
Failure to provide data may prevent:

• implementation of the service,
• Meeting legal requirements,
• handling of requests or verification.

DATA PROTECTION MEASURES

We use, among others:

• encryption,
• access control,
• network security,
• security audits,
• confidentiality obligations for staff.

DATA PROTECTION OFFICER

No formal Data Protection Officer has been appointed.
For privacy matters, please use the contact form:
Bitcoin ATM.com/contact

ABBREVIATIONS

YOU – the natural person whose data is being processed.
WE / US / OUR – Fujara Networks s.r.o.

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