Pascal Trading :: Privacy Policy

Our Privacy Policy

Pascal Trading Privacy Policy

Last updated Dec 20, 2022

This Privacy Policy of Pascal Trading ("Pascal Trading," " us," "we," and "our") describes the information we collect about you when you access our website or web application, enter into agreements with us, use our services and products, send us communications, or otherwise engage with us, and what we do with such information. Any references to Pascal Trading in this Privacy Policy also refer to its wholly owned subsidiaries. This Privacy Policy covers all of our services and products and all methods by which you may access our website or web application.

By opening an account with us and utilizing our services, products, website, and web application, you agree to the terms of our Privacy Policy. If you do not agree to the terms of our Privacy Policy, you cannot use our services or products and should not access our website or web application.

We understand that privacy is an important issue to you, and we respect the privacy of our consumers, clients, and users. We aim to protect the security and conﬁdentiality of Personal Information about you that we acquire.

Under the law you have the right to limit some, but not all, sharing of your Personal Information. The law also requires us to disclose to you how we collect, share and protect your Personal Information.

Please see our Privacy Notice for additional information about how we use and share information we obtain to provide services and products.

Personal Information We Collect:

For the purposes of this Privacy Policy, Personal Information is information that can reasonably identify, relate to, describe, be associated with, or reasonably be associated with a particular individual or household. Personal Information also includes information that may be classiﬁed as "Personal Data" or "Personally Identiﬁable Information" in some jurisdictions. This Privacy Policy does not apply to anonymized data as it cannot be used to identify you.

We may collect, store, use, and transfer the following types of Personal Information:

Identity Data such as your name, address, telephone and mobile phone number, date of birth, government issued identiﬁcation, tax identiﬁcation number, cryptocurrency wallet address(es);

Transaction Data such as information relating to your transactions, including details regarding cryptocurrency wallet addresses or related information for deposits or withdrawals;

Financial Data such as bank name, bank account number, information that may be received from consumer reporting agencies (e.g., credit bureau reports);

Online/Device Data such as IP address and device type; and

Audio/Visual Data such as phone conversations and photographs.

Other Information We Collect:

We also collect other information in the form of aggregated statistics that does not uniquely identify you as an individual. This information is referred to as "deidentiﬁed information". We collect deidentiﬁed information when you interact with us and use our services and products. Examples may include trafﬁc visits on the website and web application, information on the links you click, the features of our website that you use, and the types of information you upload. We may share deidentiﬁed information with our advertising and marketing agents to evaluate the effectiveness of our marketing programs. Additionally, we may use this information to analyze your usage of our website and for other research that help us improve the services and products we offer.

How We Collect Your Personal Information:

We collect your Personal Information from the following sources:

Direct Interactions. You provide your Personal Information when you use our services and products, open an account with us, request marketing information, enter a sweepstakes, or contact us with questions or requests.

Technological Interactions. When you use our services and products, we automatically collect Personal Information through cookies (see Cookies).

Third Parties. We collect Personal Information from third parties as required or permitted by applicable law. Third-party sources may include public databases, credit bureaus, identity veriﬁcation partners, resellers and channel partners, joint marketing partners, and social media platforms. We also receive Personal Information about you from third parties who you have authorized to disclose information about you that we need for the user and borrower account (i.e., Pascal Trading account) opening process, to satisfy our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, and for effecting transactions for and the operations in your account. Additionally, we receive Personal Information when you link a third-party service to our services. Such linkage may include interactions with our social media sites. Third-party sites are governed by their own privacy policies, and you should review those privacy policies before using those sites.

Why We Collect and Use Your Personal Information:

We only collect and use your Personal Information, as required or permitted by applicable law, for the following purposes:

In connection with our provision of services and products to you in order to meet our contractual obligations to you;
Where it is necessary for our legitimate interests. For example, conducting background checks for Know Your Customer (KYC) reviews and Anti-Money Laundering (AML) Watchlists, sending you notices regarding your money/cryptocurrency transfers to and from Pascal Trading, sending you conﬁrmations and other information on your cryptocurrency transactions, to create your account statements, maintaining records on your transactions and providing support to your account generally;
To deliver content about our services and products, and to send promotional and other information to you; and
To conduct analysis regarding your usage of our services and products and the effectiveness of our marketing initiatives.

We will not use your Personal Information for purposes other than those purposes we have disclosed to you without your permission. If we need to use your Personal Information for an unrelated, new, or additional purpose, we will notify you and obtain your consent to use it for such unrelated, new, or additional purpose.

Legal Basis for Collecting and Using Your Personal Information:

We rely on the following legal bases, as required by applicable law, to collect and use your Personal Information:

Where collection and use of your Personal Information is necessary for the performance of a contract (e.g., using your information to deliver a purchased service or product);
Where the collection and use of your Personal Information is required to comply with the law;
Where the collection and use of your Personal Information is necessary for our legitimate interest provided it does not override your rights and freedoms; and
Where you have given us your consent to collect and use your Personal Information.

Sharing Your Personal Information:

We do not disclose your Personal Information to any third parties, except to those who require access to the data in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. This may include but is not limited to, any obligations of Pascal Trading, and in order to facilitate the execution of our clients’ cryptocurrency transactions in the ordinary course of business.

We share the categories of Personal Information as outlined in "Personal Information We Collect" with the following categories of third parties:

Our Afﬁliates. We may share Personal Information with Pascal Trading afﬁliates that distribute or market Pascal Trading using this information in accordance with this Privacy Policy.

Service Providers. Pascal Trading engages with ﬁnancial, accounting, legal, marketing, and technology companies to provide services such as data processing, administrative services, regulatory support, legal services, liquidity services, bank services, cloud storage, authentication support, payment processing, technical support, sales, client support, data hosting, marketing analytics auditors, accountants, cryptocurrency exchange and custodians, cryptocurrency forensic analysis services.

Regulatory and Government Authorities. We may share your Personal Information with law enforcement, regulatory agencies, and self-regulatory agencies to help prevent fraud, for legal proceedings, or as required by law.

We transfer, disclose, or allow access to your Personal Information to afﬁliate companies and third parties for the purposes described below:

We may disclose Personal Information to third parties in order to administer or process a transaction, product or service you have authorized or requested, or in the context of facilitating the execution of a transaction.
We are required to validate our clients’ identities by applicable laws and regulatory requirements and rely on third-party services to perform these validations. Personal Information that you provide to us during the account opening process is passed to these services at account opening and on an ongoing basis thereafter.
We provide Personal Information that you provide during the account opening process, as required by applicable laws and regulatory requirements, to carry out or aid in certain functions, such as, but not limited to, account processing, surveillance, reconciliation, execution, document retention requirements, and document dissemination.
We share your information with ﬁnancial institutions with which we partner to process payments which you have authorized.
We may share analyses based on anonymous client information or behavior with our afﬁliate companies in order to operate and improve products and services.
We may disclose or transfer information we collect to a purchaser of our business.
We may disclose or transfer information we collect upon account closing where you have a deﬁcient balance, or upon excessive instances where you do not have sufﬁcient funds in your account.
We may disclose Personal Information should you decide to participate in certain promotions and special offers when the nature of the promotion or special offer requires us to gather and share your Personal Information (such as your mailing address) with a third- party for delivery of goods or services. Should you choose to purchase a product or service offered by another company by way of a promotion or special offer, any Personal Information you share with that company would no longer be governed by our Privacy Policy.
We may disclose Personal Information to third parties that provide services, such as, but not limited to, consulting, sales, client support operations, payment processing, authentication services, and technical support or services.
We may share your information with law enforcement, and ofﬁcials, or other third-parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of Personal Information is necessary to prevent physical harm or ﬁnancial loss, to report suspected illegal activity or to investigate violations of any of our terms and conditions or any other applicable policies.
We may disclose information to third parties about your account or the transactions you make if you give us your written permission.

Other circumstances under which we may disclose your Personal Information include to:

Comply, as necessary, with applicable laws and regulatory requirements, as well as legal process;
Respond to mandatory legal or governmental requests or demands for information; Meet national security requirements;
Enforce our agreements, policies, procedures and/or terms of use;
Protect ourselves, our afﬁliates, our clients, our counterparties or the general public from illegal activities; and
Respond to an emergency that requires disclosure of speciﬁed.

If an afﬁliate company or a third party needs access to certain Personal Information to carry out certain functions on our behalf, they do so under our instructions. All afﬁliates and third parties with whom we share Personal Information have their own privacy policies; however, they are expected to protect this information in a manner that aligns with the protocols described in this Privacy Policy. We do not share Personal Information with afﬁliates for their own beneﬁt, unless you have given us your consent. Additionally, we do not share your Personal Information with third parties for their beneﬁt.

Opting Out of Sharing Your Personal Information:

From time to time, we may request your permission to allow us to share your Personal Information with third parties. You may opt out of having your Personal Information shared with third parties, or from allowing us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your Personal Information, certain features or Pascal Trading services may not be available to you.

Third-Party Websites

We may have links to unafﬁliated third-party websites on our website. These third-party websites have their own privacy policies. We have no involvement with their policies and are not responsible for their practices. You are encouraged to review the privacy policies of all third-party websites you visit.

Marketing Communication

We, or our service providers on our behalf, may use your Personal Information to send you marketing and promotional communication that we believe may enhance your experience with our services or products, or may be of interest you. If you do not want to receive marketing and promotional communication from us, you can opt-out at any time by contacting us, or by unsubscribing via the links provided in the marketing emails.

Sale of Your Personal Information

Currently, we do not sell your Personal Information.

Personal Information of Minors

Our services and products are not intended for individuals under the age of eighteen (18). We do not knowingly collect and use Personal Information related to minors.

Use of Cookies

Cookies are small text ﬁles sent from a site to the hard drive of a user's device to store bits of information related to that user or device. First-party cookies are put on your device directly by our website, which allows us to collect analytical data and provide other useful functions that create a good user experience. Third-party cookies are placed on your device by a third party (e.g., advertiser or analytic system). The third parties who serve cookies on our site may link your name or email address to other information they collect, which may include past purchases made ofﬂine or online, or your online usage information.

Pascal Trading uses cookies in order to provide better service, to facilitate use of our website, to track usage of our website, to collect data, and to address certain security issues. When you access our website, we send the cookies to your computer or phone. Your computer or phone stores the cookie in a ﬁle located inside your web browser. The cookies help Pascal Trading keep track of your visits to our website and your activity on our website to understand how you interact with us.

We may link the information collected by cookies with other information we collect from you pursuant to this Privacy Policy and use the combined information as set forth herein.

We use the following types of cookies:

Functional Cookies allow our website to provide enhanced functionality. For example, we use these cookies to notify you of account updates, notiﬁcations, and reminders. You may refuse to accept these cookies; however, this may affect access to certain parts of our website. Additionally, you may not be able to take advantage of personalized features.

Performance Cookies collect information about how you use our website, for example, which pages you visited and which links you clicked on. The information collected is aggregated and cannot be used to identify you.

Marketing Cookies may be set on our website by our advertising and marketing service providers. They are used to track your online activities and help us provide relevant advertising, links, or other information about our services and products to users visiting other websites after visiting our website.

Name of cookie	Function of cookies	Name of provider	Type of coookie	Duration of the cookie
Google Ads	Analytics, Caching, Ads	Google	Persistent	2 years
Google Analytics	Analytics	Google	Persistent	2 years

You can generally activate or later deactivate the use of cookies through a functionality built into your web browser. If you want to learn more about cookies, or how to control, disable or delete them, please visit https://www.aboutcookies.org for detailed guidance. The following link explains how Google uses data when you use its partners’ websites and applications: www.google.com/policies/privacy/partners/. Certain third-party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing.

Security

Pascal Trading strives to ensure that our systems are secure and that they meet industry standards. We seek to protect non-public Personal Information that is provided to Pascal Trading by third parties and you by implementing physical and electronic safeguards. Where we believe appropriate, we employ ﬁrewalls, intrusion prevention, encryption technology, user authentication systems (i.e. passwords and personal identiﬁcation numbers) and access control mechanisms to control access to systems and data. Pascal Trading endeavors to engage third-party service providers that have security and conﬁdentiality policies, if such third-party service providers have access to our client’s Personal Information. We instruct our employees to use strict standards of care in handling the personal ﬁnancial information of clients. As a general policy our staff will not discuss or disclose information regarding an account except with authorized personnel of our service providers or as required by applicable law and regulatory requirements law or pursuant to regulatory request and/or authority.

Despite our efforts to protect the security of your information, no security system is always effective, and we cannot guarantee that our systems will be completely secure.

Retention

We are required under applicable laws and regulatory requirements to retain certain information, including Personal Information of clients, client proﬁles, identiﬁcation veriﬁcation materials, information we used to satisfy our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, account information, account agreements, trade orders, trade conﬁrmations and other agreements between us, account statements, and other records.

Such records are generally retained as required by law, rule or regulation or for the minimum amount of time necessary to accomplish the purpose for which it was collected, and thereafter no longer than is permitted under Pascal Trading’s data retention policies.

However, even after you deactivate your account, we can retain copies of information about you and any transactions or services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our services and products, to assist with investigations, to enforce any of our terms and conditions or other applicable agreements or policies, or to take any other actions consistent with applicable law.

Your Privacy Rights

Depending on the jurisdiction where you reside, you have certain rights over the Personal Information we collect about you. You may exercise the rights, based on the applicable jurisdiction, at any time by logging into your account and clicking the Proﬁle & Security tab or by contacting us. Note that we may refuse to grant your requests in whole or in part as permitted by applicable law.

If you close your Pascal Trading account, we will mark your account in our database as "Closed," but will keep your account information in our database for a period of time described in "Retention". This is necessary in order to deter fraud by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your Personal Information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

European Union (EU) Residents:

The General Data Protection Regulation (GDPR) allows individuals residing in the EU, or who are citizens of the EU, certain rights over their Personal Information. To exercise these rights, please contact us. These rights include:

Right to Access. You may request we provide you a copy of the Personal Information we hold about you and certain information about our processing of this information.

Right to Rectify. You may request we update or correct inaccuracies in your Personal Information or complete it if necessary.

Right to Erasure. You may request we delete your Personal Information from our records subject to certain exceptions. For example, we may deny your request if retaining your Personal Information is required under certain circumstances, including but not limited to: complying with a legal obligation; establishing, exercising or defending legal claims; or performing a task in the public interest or in the exercise of ofﬁcial authority.

Right to Data Portability. You may request we transfer a machine-readable copy of your Personal Information to you or a third party of your choice. We will provide you, or a third party, your Personal Information in a machine-readable format. This right only applies to Personal Information you have consented for us to use.

Right to Restrict Processing. You may request we restrict or suppress the processing of your Personal Information under certain circumstances: to establish the accuracy of the Personal Information; where the processing is unlawful, but you do not want your Personal Information erased; where we no longer need to process your Personal Information, but the information must be retained for legal reasons; and where you have objected to our processing your Personal Information, but we need to determine whether our legitimate interest overrides your objection.

Right to Object. You may object to our reliance on our legitimate interests as the basis of our processing of your Personal Information that impacts your rights. You also may object to our process of your Personal Information for direct marketing purposes.

Right to Withdraw Consent ("Opt-out"). You may withdraw your consent at any time where we are relying on it to process your Personal Information. Withdrawing your consent does not affect the lawfulness of our processing of your Personal Information prior to withdrawing.

Information We May Need from You

We may need to request speciﬁc information from you (e.g. name and email address) to help us conﬁrm your identity and verify your request. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it, and that your Personal Information is not deleted at the request of anyone but you. We may also contact you to ask you for further information in relation to your request.

Time to Respond to Your Requests

We try to respond to all legitimate and veriﬁable requests within thirty (30) days. Occasionally, it may take us longer than thirty (30) days if your request is particularly complex, you have made several requests, or additional information is needed from you to process your request. In this case, we will notify you within the thirty (30)-day period and keep you updated.

If you have an account with us, we may deliver our response to that account. If you do not have an account with us, we will deliver our response by mail or electronically. If we cannot comply with your request, we will provide a detailed explanation of why we cannot comply.

Fees

You will usually not have to pay a fee to exercise any rights listed above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may refuse to comply with your request under these circumstances.

In addition to the rights listed above, you also have the right to lodge a complaint with your local Supervisory Authority if you believe that our processing of your Personal Information does not comply with the GDPR. You also have the right to make a complaint to the Information Commissioner’s Ofﬁce (ICO):

Wycliffe House
Water Lane
Wilmslow Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk

We would appreciate the chance to deal with your concerns, so please contact us if you have any issues or complaints with our processing of your Personal Information.

California Privacy Rights (Applicable to California Residents)

California Consumer Privacy Act (CCPA) The CCPA went into effect on January 1, 2020. It affords California residents speciﬁc rights over their Personal Information. To exercise these rights, please contact us. These rights include:

Right to Notice. You have the right to receive notice, before or at the point of collection, about the categories of Personal Information we collect and its intended purpose. We may not collect additional Personal Information categories or use collected Personal Information for unrelated, new, or additional purposes without providing notice to you.

Right to Know and Access. You have the right to know and access the categories of Personal Information collected, the speciﬁc types of Personal Information collected, the categories of sources from which Personal Information is collected, the business or commercial purpose for collecting and/or disclosing the Personal Information, the categories of Personal Information sold or disclosed, the categories of third parties to whom the Personal Information was sold or disclosed, and the business or commercial purpose for collecting or selling Personal Information. Additionally, you have the right to receive this information in a portable, useable, and machine- readable format.

Right to Deletion. You have the right to request deletion of your Personal Information subject to certain exceptions. For example, we may deny your request if retaining your Personal Information is required under certain circumstances such as: to complete the transaction for which we collected the Personal Information, provide goods or services that you requested; take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; or comply with a legal obligation.

Non-Discrimination. You have the right to not face discrimination for asserting your rights subject to certain parameters. Under the CCPA, we may not take retaliatory or discriminatory actions against any consumer who chooses to exercise any of these rights. Thus, we cannot deny you our Service. The law prohibits any practices that are usurious, coercive, or unjust.

Opt-Out of the Sale of Personal Information. You have the right to opt-out of the sale of your Personal Information. However, since we do not sell your Personal Information, there is no need for you exercise this right.

Information We May Need from You

We may need to request speciﬁc information from you (e.g. name and email address) to help us conﬁrm your identity and verify your request. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it, and that your Personal Information is not deleted at the request of anyone but you unless the individual is your authorized agent. We may also contact you to ask you for further information in relation to your request.

Time to Respond to Your Requests

We try to respond to all legitimate and veriﬁable requests within forty-ﬁve (45) days. Occasionally it may take us longer than forty-ﬁve (45) days if your request is particularly complex, you have made several requests, or additional information is needed from you to process your request. In this case, we will notify you within the forty-ﬁve (45)-day period and keep you updated.

Please note, we are not required to action requests to access your Personal Information more than twice in a 12-month period.

Fees

Authorized Agents

You can authorize a designated agent to exercise your rights on your behalf. To authorize a designated agent please contact us.

California Shine the Light (California Civil Code 1798.83)

California residents, who have an established business relationship with us, may request that we disclose the categories of Personal Information we share with third parties, if any, for the third parties’ direct marketing purposes, and the list of third parties to whom the Personal Information was shared in the preceding calendar. To request this disclosure, please contact us. Please note, the request is free of charge and we are required to respond to one request per California resident each year.

California Financial Information Privacy Act

The California Financial Information Privacy Act limits what we can do with your ﬁnancial information and gives you rights to limit our sharing of your ﬁnancial information. Under the California Financial Information Privacy Act, California residents have the right to: receive notice and opt-in to us sharing non-public Personal Information with non-afﬁliated third parties; receive notice and opt-out of sharing non-public Personal Information with afﬁliates; and opt-out of Personal Information sharing resulting from joint-marketing agreements with non-afﬁliated third parties to market ﬁnancial products and services.

We do not share your information with afﬁliates and non-afﬁliated third parties, except for certain business purposes (e.g., to service your accounts), to market our products and services, as permitted by law, or with your consent. You can access our Privacy Notice for information about our practices in accordance with the California Financial Privacy Act. Please contact us to opt-in to, or opt-out of, sharing your non-public Personal Information.

California "Do Not Track" Policy

California law requires us to inform you how we respond to web browser Do Not Track ("DNT") signals. Because no industry or legal standard exists for recognizing or honoring DNT signals, we do not respond to them at this time. This Privacy Policy is subject to change as the privacy community and industry develop best practices for responding to DNT signals.

Vermont Privacy Rights (Applicable to Vermont Residents)

Vermont Financial Privacy Act

The Vermont Financial Privacy Act limits what we can do with your ﬁnancial information and gives you rights to limit our sharing of your ﬁnancial information. Under the Vermont Financial Privacy Act, Vermont residents have the right to receive notice and opt-in to sharing non-public Personal Information with non-afﬁliated third parties. Additionally, residents must consent to us sharing information regarding credit worthiness.

We do not share your information with afﬁliates and non-afﬁliated third parties, except for certain business purposes (e.g., to service your accounts), to market our products and services, as permitted by law, or with your consent. Additionally, we will not disclose credit information about you with our afﬁliates or non-afﬁliated third parties, except as required or permitted by law. You can access our Privacy Notice for information about our practices in accordance with the Vermont Financial Privacy Act. Please contact us to opt-in to, or opt- out of, sharing your non-public Personal Information.

When Do We Store, Transfer or Process Your Personal Information Internationally?

Pascal Trading has committed to meeting the requirements of local data protection laws, including EU law, to the extent required. Please be aware that your Personal Information will be transferred to, processed, and stored in our data servers located within the United States. You consent to the transfer of your information, including Personal Information, to the U.S. as set forth in this Privacy Policy by visiting our site or using our service.

Changes to Pascal Trading’s Privacy Policy

This Privacy Policy is available on our website at https://www.pascaltrading.com. Pascal Trading reserves the right to make changes to this Privacy Policy. You should review our Privacy Policy frequently. If we make material changes to our Privacy Policy, our revised Privacy Policy will be posted on our website and it will either be noted on our website that material changes have been made or we will notify our clients by email. The date of the most recent update to our Privacy Policy will be set forth at the end of this Privacy Policy.

How to Get in Touch with Pascal Trading

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you should ﬁrst contact us by emailing us at privacy@pascaltrading.com

If you would like to submit a complaint about our use of your Personal Information or response to your requests regarding your Personal Information, you may contact us at support@pascaltrading.com

Last Updated: 12/20/2022