For the purpose of the applicable data protection laws, the data controller is Bitit SAS company having its registered ofﬁce in 25 rue du Petit-Musc, 75004 Paris - France and registered with the Trade and company register of Paris, France under the number 810 222 513.
You are not limited to registered members, as well as any visitor who uses the Website in any way, shape or form.
So, please read the following carefully to understand our views and practices regarding Your Personal Data and how we will treat it.
1 ― Gathering Personal Information
In order to comply with KYC and anti-money laundering regulations, Bitit may request certain information from registered Users, including Your name, date of birth, address, post code, country, city, e-mail address, government issued ID, or any other personally identifiable information.
Furthermore, Bitit may request such information to prevent fraud, and to protect Bitit in any way that we seem reasonable in accordance with Bitit SAS Anti Money Laundering ("AML") and Counter Terrorist Financing ("CTF") policy as detailed below.
Money laundering is defined as the process where the identity of the proceeds of crime is so disguised that it gives the appearance of legitimate income.
Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm's knowledge or suspicions.
Within Europe alone it is estimated that billions of euros are laundered on an annual basis and on globally in revenue terms the amount of money laundered would make it the third largest industry.
In response to the scale and effect of money laundering, Europe and its member countries, has passed legislation designed to prevent money laundering and to combat terrorism.
This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for European firms and outline the offences and penalties for failing to comply.
Whilst Bitit is currently unregulated and do not fall with the scope of the AML/CTF obligations as in the 3rd and 4th AML Directive and PSD Framework, the Bitit senior management and its shareholders have implemented systems and procedures that meet the European AML legislation.
This decision reflects the senior managements desire to prevent money laundering and not be used by criminals to launder proceeds of crime.
2 ― For which purposes We may collect personal information ?
Bitit may collect and use personal information for the following purposes:
- To protect our system from fraud
- To comply with KYC regulations
- To provide and improve customer service
- To send periodic emails
- To contact Users using any means that we deem necessary
- To process payments
- To comply with any provincial or national law
- To carry out the regular business activities of Bitit
We may also collect information about Your computer or other device, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and will not be used to identify any individual.
3 ― Anti-Money Laundering (AML) Policy
The Bitit AML Policy is designed to prevent money laundering by meeting the Europe AML/CTF legislation and its obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime.
This AML Policy sets out the minimum standards which must be complied with and includes:
- The appointment of a Head of Risk Management and Compliance who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
- Establishing and maintaining a Risk-Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
- Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
- Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
- Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
- The maintenance of appropriate records for the minimum prescribed periods;
- Training and awareness for all relevant employees.
4 ― Sanctions Policy
Bitit is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists.
Bitit will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.
5 ― What do We do with Your personal information in connection with AML Policy ?
Bitit reserves all right to share any information in its possession with any relevant third party, as soon as Bitit has a reasonable doubt about a suspicious activity in relation with Money Laundering or Terrorism Financing. Following, Your personal information are disclosed to third parties providing fraud prevention, fraud screening and age and/or identity verification services Us.
For this purpose, Your personal information including your full name and address, your bank account and card payment details, gender and contact telephone numbers may be used for fraud prevention, fraud screening and age and identity verification purposes. In this regards, Your personal information may be disclosed to and used by fraud prevention agencies (“FPAs”) for all such purposes and those agencies may keep a record of it where permitted by applicable data protection laws.
You should not confirm Your order or tick the relevant box on Our Website unless You consent to this use of Your personal information.
As part of this, We may check the following records about You:
- Our own records;
- Records held by third parties providing services to us;
- Records at fraud prevention agencies (FPAs).
The checks described above may include assessing and verifying identities to prevent and detect fraud. The information We obtain from third parties providing services to Us and FPAs will help Us to decide whether we are willing to accept orders and/or payments from You through our Website and whether to complete the order and/or payment process through Our Website.
As explained above, personal information about You may be sent by Us to FPAs and recorded by them. In addition, We may give details of the orders and/or payments You make to FPAs. All such information may be supplied by the FPAs to other organisations in order that they may perform similar fraud prevention, fraud screening and age and identity verification checks against You, including as part of online transactions and otherwise.
If You give us false or inaccurate personal information about Yourself and /or if We have a reasonable doubt about a suspicious activity in relation with Money Laundering or Terrorism Financing and / or if We suspect fraudulent orders and/or fraudulent payments and/or identity fraud We will record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention. We and other organisations may access and use information which relates to You and which is recorded by FPAs in other countries.
Except the above, We will not share Your personal information with any government agency, unless required to do so by law.
This section constitutes a short form explanation about how Your personal information may be used by Us in conjunction with the AML Policy and the FPAs. If You would like to obtain full details about this, please contact Us at [email protected]
When You access Our Bitit’s Website or content or use Our Bitit’services, We may place small data files called cookies or pixel tags on Your computer or other device. We use these technologies to:
- Recognize you as a Bitit’s subscriber;
- Customize Bitit’services, content, and advertising;
- Measure promotional effectiveness;
- Collect information about Your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.
6 ― Storage of Personal Information
We use both session and persistent cookies when You access our website or content. Session cookies expire and no longer have any effect when You log out of Your account or close your browser. Persistent cookies remain on Your browser until You erase them or they expire.
We encode our cookies so that only We can interpret the information stored in them. You are free to decline Our cookies if Your browser or browser add-on permits, but doing so may interfere with Your use of Bitit’s services.
8 ― How We provide You with the best possible User experience
Your personal information may be shared with any division of Bitit or its subsidiaries in order to provide the best possible User experience.
If You are a new subscriber to the Bitit’s Website, We reserve the right to contact You for marketing purposes by electronic means only if You have consented to this. The same applies if We would like to share Your data with selected third parties for their marketing purposes. You may revoke Your consent at any time by sending an email to [email protected]
We do not disclose personal information about identifiable Bitit’s Users to Our partners but We may provide them with aggregate information about our Website’s Users experience. We may also use such aggregate information to help our partners (as for example, merchants) reach the kind of objectives they want to target regarding Bitit’s gift cards.
9 ― Access to Your Personal Data
According to the Data Protection Act of January 6th, 1978, you have at any time, a right of access to and rectification of all of your personal data.
You can access to your personal data linking to Your Profile or by contacting: [email protected]
11 ― Contact Us about Privacy questions