provider of this Website. Coinamp Limited takes the privacy of your information very seriously. This
your use of the Website.
Coinamp Limited is committed to respecting the privacy of our users as well as protecting your personal
This document, in conjunction with the Terms and Conditions for this website will enable Coinamp to
adhere to applicable legislation and regulation as well as to discharge our duties in an ethical manner.
Our policy complies with UK law accordingly implemented, including that required by the EU General Data
Protection Regulation (GDPR).
We confirm for the purposes of the data protection laws, that Coinamp Limited is a data controller of
the personal data in connection with users. This means that we determine the purposes for which, and the
manner in which, your personal data is processed.
The law requires us to tell you about your rights and our obligations to you in regards to the
processing and control of your personal data. We do this now, by requesting that you read the
information provided at www.ico.org.uk or www.knowyourprivacyrights.org.
By disclosing your personal information to Us, including, but not limited to, by using the Platform,
contacting Us through any communication channel, you consent to the collection, storage, and processing
Definitions and interpretation
collectively all information that you submit to Coinamp Limited via the Website. This
definition incorporates, where applicable, the definitions provided in the Data Protection
Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited
to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national
implementing laws, regulations and secondary legislation, for as long as the GDPR is effective
in the UK;
the General Data Protection Regulation (EU) 2016/679;
Coinamp Limited, or us
Coinamp Limited, a company incorporated in England and Wales with registered number
11318760 whose registered office is at 1-2 Charterhouse Mews, London, United Kingdom, EC1M
User or you
any third party that accesses the Website and is not either (i) employed by Coinamp
Limited and acting in the course of their employment or (ii) engaged as a consultant or
otherwise providing services to Coinamp Limited and accessing the Website in connection with
the provision of such services; and
the website that you are currently using, https://counter.market, and any sub-domains of
this site unless expressly excluded by their own terms and conditions.
- a.the singular includes the plural and vice versa;
- b.references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses,
- c.a reference to a person includes firms, companies, government entities, trusts and
- d."including" is understood to mean "including without limitation";
- e.reference to any statutory provision includes any modification or amendment of it;
this Website. It does not extend to any websites that can be accessed from this Website including,
but not limited to, any links we may provide to social media websites.
- 4.For purposes of the applicable Data Protection Laws, Coinamp Limited is the "data
controller". This means that Coinamp Limited determines the purposes for which, and the manner in
which, your Data is processed.
- 5.We collect personal information to provide you with our Services. When we require certain
personal information from users it is because we are required by law to collect this information or
it is relevant for specified purposes. Any information you provide to us that is not required is
voluntary. You are free to choose whether to provide us with the types of personal information
requested, but we may not be able to serve you as effectively or offer you all of our Services when
you do choose not to share certain information with us.
- 6.We collect personal information which is required to open an account, link wallets, or
execute transactions. We also collect personal information when you use or request information about
our Services, subscribe to marketing communications, request support, complete surveys, or sign up
for an event. We may use this information in combination with other information we collect about you
as set forth in this Policy.
We may collect the following types of information:
- a.Personal Identification Information: Full name, date of birth, age, nationality,
gender, signature, identifying documents, phone number, home address, and email.
- b.Formal Identification Information: Tax ID number, passport number, driver’s
license details, national identity card details, photograph identification cards and registration
- c.Financial Information: Wallet address, transaction history, trading data.
- d.Transaction Information: Information about the transactions you make on our Services,
such as your name, recipient details, the amount, and/or timestamp.
- e.Employment Information: Office location, job title, and/or description of
- f.Online Identifiers: Geo location/tracking details, browser fingerprint, OS, browser
name and version, and/or personal IP addresses.
- g.Usage Data: Survey responses, information provided to our support team, public social
networking posts, authentication data, security questions, user ID, click-stream data and other
How data is used
- 7.Our primary purpose in collecting personal information is to provide you with a secure,
smooth, efficient, and customised experience. In general, we use personal information to create,
develop, operate, deliver, and improve our Services, content and advertising, and for loss
prevention and anti-fraud purposes. We may use this information in the following ways:
- a.To maintain legal and regulatory compliance - Some of our core Services
are subject to laws and regulations requiring us to collect and use your personal identification
information, formal identification information, financial information, transaction information,
employment information, online identifiers, and/or usage data in certain ways. For example, we
must identify and verify customers using our Services to comply with anti-money laundering and
terrorist financing laws across jurisdictions. In addition, we use third parties to verify your
identity by comparing the personal information you provided against third-party databases and
public records. When you advance your trading limits associated with your account, we may require
you to provide additional information which we may use in collaboration with service providers
acting on our behalf to verify your identity or address, and/or to manage risk as required under
applicable law. The consequences of not processing your personal information for such purposes is
the termination of your account as we cannot perform our Services in accordance with legal
- b.To enforce our terms in our user agreement and other agreements
– We handle very sensitive information, such as your identification data, so it
is very important for us and our customers that we are actively monitoring, investigating,
preventing and mitigating any potentially prohibited or illegal activities, enforcing our
agreements with third parties, and/or violations of our posted user agreement or agreement for
other Services. In addition, we may need to collect fees based on your use of our Services. We
collect information about your account usage and closely monitor your interactions with our
Services. We may use any of your personal information collected on our Services for these
purposes. The consequences of not processing your personal information for such purposes is the
termination of your account as we cannot perform our Services in accordance with our terms.
- c.To provide our Services - We process your personal information in order
to provide the Services to you. For example, when you want to buy a digital asset, we require
certain information such as your identification, contact information, and payment information. We
cannot provide you with Services without such information.
- d.To provide Service communications - We send administrative or
account-related information to you to keep you updated about our Services, inform you of relevant
security issues or updates, or provide other transaction-related information. Without such
communications, you may not be aware of important developments relating to your account that may
affect how you can use our Services.
- e.To provide customer service - We process your personal
information when you contact us to resolve any questions, disputes, collect fees, or to
troubleshoot problems. We may process your information in response to another customer’s
request, as relevant. Without processing your personal information for such purposes, we cannot
respond to your requests and ensure your uninterrupted use of the Services.
- f.To ensure quality control - We process your personal information for
quality control and staff training to make sure we continue to provide you with accurate
information. If we do not process personal information for quality control purposes, you may
experience issues on the Services such as inaccurate transaction records or other interruptions.
Our basis for such processing is based on the necessity of performing our contractual obligations
- g.To ensure network and information security - We process your personal
information in order to enhance security, monitor and verify identity or service access, combat
spam or other malware or security risks and to comply with applicable security laws and
regulations. The threat landscape on the internet is constantly evolving, which makes it more
important than ever that we have accurate and up-to-date information about your use of our
Services. Without processing your personal information, we may not be able to ensure the security
of our Services.
- h.For research and development purposes - We process your personal
information to better understand the way you use and interact with our Services and use such
information to customise, measure, and improve our Services and the content and layout of our
website and applications, and to develop new services. Without such processing, we cannot ensure
your continued enjoyment of our Services. We process this information based on legitimate
- i.To enhance your website experience - We process your personal information
to provide a personalised experience, and implement the preferences you request. For example, you
may choose to provide us with access to certain personal information stored by third parties
Without such processing, we may not be able to ensure your continued enjoyment of part or all of
our Services. We process this information based on legitimate interest.
- j.To facilitate corporate acquisitions, mergers, or transactions - We may
process any information regarding your account and use of our Services as is necessary in the
context of corporate acquisitions, mergers, or other corporate transactions. You have the option
of closing your account if you do not wish to have your personal information processed for such
- k.To engage in marketing activities - Based on your communication
preferences, we may send you marketing communications to inform you about our events or our
partner events; to deliver targeted marketing; and to provide you with promotional offers based on
your communication preferences. We use information about your usage of our Services and your
contact information to provide marketing communications. You can opt-out of our marketing
communications at any time.
- 8.We will not use your personal information for purposes other than those purposes we have
disclosed to you, without your permission. 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 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 authorisation. If you choose to so limit the use of your personal information, certain
features or Services may not be available to you.
Data collected automatically
- 9.We receive and store certain types of information automatically, such as whenever you
interact with the Sites or use the Services. This information does not necessarily reveal your
identity directly but may include information about the specific device you are using, such as the
hardware model, device ID, operating system version, web-browser software (such as Firefox, Safari,
or Internet Explorer) and your Internet Protocol (IP) address/MAC address/device identifier.
Keeping Data secure
- 11.We understand how important your privacy is, which is why we maintain (and requires its
service providers to maintain) appropriate physical, technical and administrative safeguards to
protect the security and confidentiality of the personal information you entrust to us.
- 12.However, we cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of
your data will not occur. Please recognise that you play a vital role in protecting your own
personal information. When registering with our Services, it is important to choose a password of
sufficient length and complexity, to not reveal this password to any third-parties, and to
immediately notify us if you become aware of any unauthorised access to or use of your
- 13.Furthermore, we cannot ensure or warrant the security or confidentiality of information you
transmit to us or receive from us by Internet or wireless connection, including email, phone, or
SMS, since we have no way of protecting that information once it leaves and until it reaches us. If
you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately
by contacting us via this e-mail address: firstname.lastname@example.org
- 14.If we discover that there has been a breach of personal data that poses a risk to the
rights and freedoms of individuals, we will report it to the Information Commissioner within 72
hours of discovery.
- 15.If the breach is likely to result in a high risk to your rights and freedoms, we will tell
affected individuals that there has been a breach and provide them with more information about its
likely consequences and the mitigation measures it has taken.
- 16.Unless a longer retention period is required or permitted by law, we will only hold your
Data on our systems for a period of 6 years, or as is necessary to fulfil the purposes outlined in
- 17.Even if we delete your Data, it may persist on backup or archival media as is necessary for
legal, tax or regulatory purposes or for reasons beyond our control.
- 18.You have the following rights in relation to your Data:
- a.Right to access - the right to request copies of the information we hold
about you at any time, or that we modify, update or delete such information where. If we provide
you with access to the information we hold about you, we will not charge you for this, unless your
request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may
refuse your request. If we refuse your request, we will tell you the reasons why. Should you make
an access request, we are in the position to disclose to you:
- whether or not your personal data is processed and if so why, the categories of personal data
concerned and the source of the data if it is not collected from you;
- to whom your personal data is or may be disclosed.
- for how long your personal data is stored (or how that period is decided);
- your rights of rectification or erasure of data, or to restrict or object to
- your right to right to complain to the Information Commissioner if you think we have failed to
comply with your data protection rights; and
- whether or not we carry out automated decision-making and the logic involved in any such
- b.Right to correct - the right to have your Data rectified if it is
inaccurate or incomplete.
- c.Right to erase - the right to request that we delete or remove your Data
from our systems.
- d.Right to restrict our use of your Data - the right to "block" us from
using your Data or limit the way in which we can use it.
- e.Right to data portability - the right to request that we move, copy or
transfer your Data.
- f.Right to object - the right to object to our use of your Data including
where we use it for our legitimate interests.
- 19.To make enquiries, exercise any of your rights set out above, or withdraw your consent to
the processing of your Data (where consent is our legal basis for processing your Data), please
contact us via this e-mail address: email@example.com.
- 20.If you are not satisfied with the way a complaint you make in relation to your Data is
handled by us, you may be able to refer your complaint to the relevant data protection authority.
For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be
found on their website at https://ico.org.uk/.
- 21.It is important that the Data we hold about you is accurate and current. Please keep us
informed if your Data changes during the period for which we hold it.
Links to other websites
- 22.This Website may, from time to time, provide links to other websites. We have no control
statement of other websites prior to using them.
Changes of business ownership and control
- 23.Coinamp Limited may, from time to time, expand or reduce our business and this may involve
the sale and/or the transfer of control of all or part of Coinamp Limited. Data provided by Users
will, where it is relevant to any part of our business so transferred, be transferred along with
be permitted to use the Data for the purposes for which it was originally supplied to us.
- 24.We may also disclose Data to a prospective purchaser of our business or any part of
- 25.In the above instances, we will take steps with the aim of ensuring your privacy is
part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will,
to the extent required, be deemed to be deleted, and the validity and enforceability of the other
- 28.Unless otherwise agreed, no delay, act or omission by a party in exercising any right or
remedy will be deemed a waiver of that, or any other, right or remedy.
- 29.This Agreement will be governed by and interpreted according to the law of England and
Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the
English and Welsh courts.
from time to time or as may be required by law. Any changes will be immediately posted on the
Website following the alterations. You may contact Coinamp Limited by email at