Privacy Statement

Last updated: 11th June 2024

Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4 In this policy, “we”, “us” and “our” refer to MCCR Marketing Ltd. For more information about us, see Section 10.

Credit

2.1 This document was created and adapted heavily based on a template from SEQ Legal

How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.

3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process (“chat data“). The chat data may include your name, email address, IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. It may also contain any other information you disclose to us during a chat conversation. The source of the chat data is Crisp.ai . The chat data may be processed for the purposes of monitoring traffic to our website, as well as direct one-to-one communications with with you. The legal basis for this processing is our legitimate interests, namely the monitoring and improving our website and services, as well as sales discussions initiated by you.

3.4 We may process your information (“sales data“). The sales data contains any personal or business information you provide to us during the course of a sales discussion, due diligence, KYC, contracting or invoicing stages. The sales data may be processed for the purposes of deciding if we will work together. The legal basis for this processing is our legitimate interests, namely the proper administration of our business.

3.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include IP information, browser information, date and time, session information, website usage information. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.6 We may process (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.

3.7 We may process information contained in any enquiry you submit to us regarding goods or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods or services to you. The sales data contains any personal or business information you provide to us during the course of a sales discussion, due diligence, KYC, contracting or invoicing stages.  The legal basis for this processing is consent.

3.8 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

3.9 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

3.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

3.11 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.12 We may process location data. This data may include IP information. The source of this data is you/the browser used while accessing this website. This data may be processed for website performance optimization. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.13 We may store and process data relating to sales meetings we have with you, including voice recordings and transcripts of calls. We will ask at the start of a call for your consent to recording this information, and transcripts or copies of the calls for the duration of time you were on it are available on request.  The source of the usage data is Fireflies.ai. This usage data may be processed for the purposes of analysing the sales process and client management processes, as well as for quality assurance. The legal basis for this processing is verbal consent.

3.14 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.15 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.16 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.17 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

Providing your personal data to others

4.1 We may disclose your personal data to any authorised member of our companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at https://bitcoinmarketingteam.com/about-bmt/.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 We may disclose service and usage data to our suppliers or subcontractors identified at https://analytics.google.com/ insofar as reasonably necessary for namely the proper administration of our website and business.

4.4 Financial transactions relating to our website and services may be handled by our payment services providers, https://stripe.com/ie . We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/ie/privacy .

4.5 We may disclose your enquiry data, with your consent, to third party suppliers of services similar to those identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services in the event we are unable to provide you a service. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 We have offices and facilities in the Republic of Ireland. However, given the nature of our online business, some of the tools we use may involve the transfer of data to services hosted within the US, or with staff located in Australia. We have a preference, wherever possible, to host our data on EU based servers. The European Commission has made an “adequacy decision” with respect to the data protection laws of the USA. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.

5.3 The hosting facilities for our website are situated within the EU. The European Commission has made an “adequacy decision” with respect to the Republic of Ireland.

5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) Service data and usage data will be retained for a minimum period of 90 days following the date you visited the website, and for a maximum period of 365 days following the date you visited the website.
(b) Enquiry data will be retained for a minimum period of 120 days following the date you contacted us via the website or email, and for a maximum period of 720 days following the date you contacted us via email or contact form on the website.
(c) Customer relationship data will be retained for a minimum period of 120 days following the date you contacted us via the website or email, and for a maximum period of 720 days following the date you contacted us via email or contact form on the website.
(d) Transaction data will be retained for a minimum period of 365 days following the date you visited the website, and for a maximum period of 720 days following the date you contacted us via email or contact form on the website.
(e) Correspondence data will be retained for a minimum period of 120 days following the date you contacted us via the website or email, and for a maximum period of 720 days following the date you contacted us via email or contact form on the website.
(f) Notification data will be retained for a minimum period of 120 days following the date you contacted us via the website or email, and for a maximum period of 720 days following the date you contacted us via email or contact form on the website.

6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of Enquiry data will be determined based on the status of the inquiry. Inquiries which have been responded to by the Bitcoin Marketing Team but did not receive a response back from the user.
(b) the period of retention of Customer relationship data will be determined based on the status of the relationship. Data of customers with an active service contract will be retained for no more than 365 days, from the day the service contract has been completed or terminated.
(c) the period of retention of Transaction data will be determined based on the status of the transaction. Data related to successful transaction will be kept for 90 days, from the day the transaction has successfully been completed. Data of incomplete transactions will be kept during the resolution phase of incomplete transactions.
(d) the period of retention of Notification data will be determined based on the delivery status of the notification.
(e) the period of retention of Correspondence data will be determined based on the status of the correspondence. Correspondence related to unresolved business matters will be kept until resolution of said matter. Correspondence related to potential future collaboration will be retained until such a collaboration seems unlikely to take place.

6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6.6 We spend some time once a year to purge all personal data, other than that related to signed contracts or other information we are required to store by law, where possible from our email systems and databases.

Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of changes to this policy by email or through the private messaging system on our website.

Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request a copy of your personal here: https://bitcoinmarketingteam.com/about-us/contact-us/

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.

About cookies

9.1 Our full cookie policy including a list of active cookies and other information is available at https://bitcoinmarketingteam.com/cookie-policy/

Our details

10.1 This website is owned and operated by MCCR Marketing Ltd.

10.2 We are registered in the Republic of Ireland under registration number 625334

10.3 Our principal place of business is at Bay 2, Unit 7a, The Digital Depot, Roe Lane, Dublin 8, D08 TCV4, Ireland.

10.4 You can contact us for any privacy policy, or GDPR related requests to:

(a) by post, to Bitcoin Marketing Team, Bay 2, Unit 7a, The Digital Depot, Roe Lane, Dublin 8, D08 TCV4, Ireland;

(b) using our website contact form: https://bitcoinmarketingteam.com/about-us/contact-us/;

(c) by email, using gdpr [at] bitcoinmarketingteam [dot] com

Data protection officer

11.1 Our data protection officer’s contact details are: Jamie McCormick, Bay 2, Unit 7a, The Digital Depot, Roe Lane, Dublin 8, D08 TCV4, Ireland.