Privacy Policy

This document sets out the Privacy Policy applicable to the website ("Website") owned by ATANI) and applies to all processing of personal data carried out as a result of the access and use of the Website and the Application. In this document we inform you and explain what personal data we process, how and when we obtain and share it, as well as the rights you can exercise.

1. Who is responsible for your personal data?

The data collected will be processed by ATANI as data controller.

Information of the Data Controller:

  1. ATANI: ETOSHI TECHNOLOGIES S.L.
  2. Address: Recoletos 3, planta 1, 28001 Madrid (Spain)
  3. VAT NO: B88388046
  4. Contact e-mail address: dataprotectionofficer@atani.com

If you have any questions about any aspect related to the processing activities of your personal data, you can contact us at the following e-mail address: dataprotectionofficer@atani.com.

2. What data do we process?

We process the following information about you:

  1. Identification data: full name, nationality, full identity card, date of birth (age), occupation, video recordings and a photographic image.
  2. Contact and communication details: telephone number, e1.mail address and postal address.
  3. Bank details (when applicable): bank name, account name, account holder, IBAN.
  4. Transaction data on goods and services: transactional information, products and services in which the User shows interest.
  5. Browsing data: IP address, domain name, unique device identifier, browser fingerprint, device fingerprint and cookie IDs where configured in your browser.

3. How do we collect your data?

We collect your personal data in different ways:

  1. By registering and/or signing up yourself as an ATANI User.

We collect your personal data when you register yourself as an ATANI User.

Please note that in order to proceed to the registration, you must provide all information marked as "required" and, on a voluntary basis, information that is "optional".

  1. Even if you are not registered as an ATANI User, through your requests for information, by any means, and/or through any other action you carry out on the Website that involves the provision of your Personal Data.

  2. Through the use of cookies.

We use different types of Cookies for the operation of the Website. For more information, please see our Cookie Policy.

4. What do we process your personal data for and what are the legal bases that legitimise us?

We may only process your personal data if we have an adequate legal basis for doing so. We may process your personal data for any or all of the purposes specified below and on the legal bases indicated:

TREATMENT AND PURPOSE LEGAL BASIS
Access and use of the Website
  1. ATANI User Registration
  2. Requests and actions carried out on the Website
  3. Send you notifications related to the provision of the service or use of the Site.
Development of the pre-contractual and/or contractual relationship and ATANI's Legitimate Interest
Sending commercial communications of products and/or services of a similar nature to those contracted by the ATANI User. ATANI's Legitimate Interest
Prevention of money laundering and terrorist financing: Identify, prevent and combat money laundering and terrorist financing and comply with applicable regulations. Legal obligation
Browsing data obtained through mandatory Cookies. Legitimate interest in preventing fraud and in the efficient provision of services and administration of the Website
Data obtained through non-essential cookies Consent
General marketing: Sending commercial communications by any means about ATANI products and services. Consent

5. With whom we share your personal data and international transfers.

In general, except in the cases indicated in the following paragraphs, we will not disclose your personal data to third parties, unless we are legally obliged to do so.

Without prejudice to the provisions of the previous paragraph, for the correct management of the Website and the services offered through the Website, your data may be communicated to

  1. Service providers on behalf of ATANI who will act as data processors.
  2. Authorities and public bodies in compliance with our legal obligations.

It is possible that some of our suppliers are located outside the European Economic Area. In this regard, ATANI will try to adopt, whenever possible, the appropriate measures in accordance with the applicable national and European legislation on data protection, such as, for example, the execution of Agreements on Data Processing with Standard Contractual Clauses.

It is also possible that our suppliers are located in the USA, which is currently classified as an insecure third country, i.e. a third country for which neither an adequacy decision pursuant to Art. 45 GDPR exists nor a comparable level of protection can be assumed. If your data is transferred to the USA, your data could be accessed and processed by the US authorities without you having to be informed or notified of this (during the processing and also after it has been completed) or being entitled to comparable legal remedies and data subjects' rights. Unfortunately, in such cases we cannot influence the processing by the US authorities.

We may also use the data obtained through your browsing in accordance with the legal basis indicated in the previous section.

6. Consent for marketing purposes and non-binding Cookies.

As stated in section 4 above, the processing of your personal data for the purpose of general direct marketing requires your express consent, which, if given, you have the right to revoke at any time.

If, at any time, you decide not to receive any commercial or promotional information from us, you may, free of charge and without providing any justification, opt-out of any direct marketing campaign and object to the future processing of your personal data for such purposes by sending us an email to dataprotectionofficer@atani.com mentioning "opt-out" in the subject line of your email. Alternatively, you can use the opt-out procedure provided in any promotional message you receive from us.

Please note that opting out of receiving promotional messages from us will not prevent you from receiving information relating to any contract you have entered into with us.

It will also be necessary, as indicated in section 4 above, your consent to the use of your data collected through non-mandatory Cookies as indicated in the Cookies Policy (LINK). This will be obtained, where applicable, through the Cookies banner at the top of the Website and/or through the Cookie Settings (LINK).

7. How long will ATANI keep the data?

Your personal data will be kept for the time strictly necessary for the purposes of the processing for which they have been provided, and, in any case, following the principle of data minimisation provided for in the applicable regulations.

If you are an ATANI User, your data will be kept for the duration of your commercial relationship with ATANI and from the moment you exercise your right to cancel your data or cancel your account, your data will be kept blocked solely for the purpose of meeting the legal responsibilities that may arise from the services provided for a period of five years.

8. How can I exercise my rights?

You can:

  1. (i) write to ATANI at the address indicated in the heading of this Privacy Policy; or
  2. (ii) send an email to the following address: dataprotectionofficer@atani.com, enclosing a photocopy of your ID document, at any time and free of charge, to:
    1. Revoke consents granted.
    2. Obtain confirmation as to whether your personal data are being processed at ATANI.
    3. Access your personal data.
    4. Rectify inaccurate or incomplete data.
    5. Request the deletion of your data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
    6. Obtain from ATANI the limitation of data processing when any of the conditions provided for in the data protection regulations are met.
    7. Request the portability of the data provided in those cases provided for in the regulations.
    8. Contact the ATANI DPO at the following address: dataprotectionofficer@atani.com.
    9. In the event that you consider that the aforementioned rights have not been properly attended to by ATANI, you may lodge a complaint with the Spanish Data Protection Agency at C/ Jorge Juan, 6, 28001 - Madrid.

9. Changes of the Privacy Policy

Our Privacy Policy may be updated due to changes and legal requirements, as well as due to improvements and changes included in the way we offer and provide our services and application utilities. Therefore, we recommend that you visit and access our Privacy Policy periodically, in order to have access to the latest changes that may have been incorporated.

In the event that such changes relate to the consent given by the User, we will send a separate and independent notification in order to collect it again.

10. Use of blockchain

The investment made of cryptoassets available through the Site will be recorded on the relevant public blockchain. Public blockchains operate like ledgers, intended to immutably record transactions on networks of computer systems. Many of these public blockchains allow forensic analysis that can lead to de-anonymisation and inadvertent disclosure of private financial information, especially when blockchain data is combined with other data.

As blockchains are decentralised or third party networks that are not controlled or operated by ATANI, we cannot delete, modify or alter personal data that is recorded on the Blockchain for the provision of the service.