Responsible Person
Data protection officer
1 Collection and Processing of Personal Data when registering to Vebitron’s website
2 Collection and Processing of Personal Data with a License
3 Collection and Processing of Personal Data via Cookies and Log Files
4 Google Analytics
5 Collection and Processing of Personal Data when using Vebitron’s Contact Form
6 Collection and Processing of Personal Data of Newsletter Recipients
7 The recipients or categories of recipients of the personal data
8 Your Rights
9 Period of Data Storage
10 Amendment of these Privacy Policy

Responsible Person:

Vebitron LLC

(in the following referred to as "Vebitron")

Vebitron collects, uses and stores user’s personal data in accordance with the applicable Data Protection

Legislation. Personal data means any information relating to an identified or identifiable natural person. Below

Vebitron informs all website users about the type, extent and purpose of the collection and use of personal data.

Terms defined in the Terms and Conditions of Vebitron shall have the same meaning here.

Sec. 1 and 2 apply to users who register and subscribe to Vebitron’s services, Sec. 3 to 10 of this Privacy

Policy apply to all visitors of Vebitron’s website.


1 Collection and Processing of Personal Data when registering to Vebitron’s website

On Vebitron’s website Vebitron offers the possibility to buy a License for The Vebitron Bitcoin Trading Terminal, a downloadable software client owned and provided by Vebitron according to its Terms and Conditions.

For purchasing the Purchaser needs to register on Vebitron’s website. For this purpose, Vebitron requests in accordance with Art. 6 para. 1 sent. 1 point b GDPR, the following data:

  • Email
  • Password
  • Country

If the Purchaser is a business user, he also has to provide Vebitron with his VAT number. Vebitron needs this data for offering its services and for invoicing. Moreover, the Purchaser may provide Vebitron the following data:

  • First and last name

If the Purchaser provides Vebitron with this data he gives his express consent that Vebitron is allowed to process this data for contract purposes. The Purchaser has the right to withdraw his consent at any time by simply deleting this data from his profile. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.


2 Collection and Processing of Personal Data with a License

When buying a License the Purchaser needs to choose a payment method. The Purchaser may chose from the following payment methods:

Payment via Coinbase

For payment using bitcoin, Vebitron uses the services of Coinbase, Inc. with legal seat in the U.S. Coinbase has NOT self-certified its adherence to the EU-U.S. Privacy Shield Framework Principles. I.e. by using Coinbase you expressly consent that your data is transferred to a company which has NOT self-certified their adherence to the EU-U.S. Privacy Shield Framework Principles.
If a Purchaser wants to pay via Coinbase, the Purchaser will be requested to fill in his email address.
This information is requested since it will enable Coinbase’s system to send an email to Purchaser directly to obtain a bitcoin refund address in case of a payment exception (e.g. overpayments, underpayments, etc.).
If an attempt to pay Vebitron fails, or is later invalidated, Coinbase may provide Vebitron with details of the unsuccessful payment. However, Vebitron is not provided by Coinbase with any other data.
For more information on how Coinbase processes Purchaser’s data, please visit Coinbase’s Privacy Policy:
https://www.coinbase.com/legal/privacy


3 Collection and Processing of Personal Data via Cookies and Logfiles

  1. In accordance with Art. 6 para. 1 sent. 1 point f GDPR, Vebitron’s website uses so-called cookies in order to make available personalized functions and in order to analyze the use of Vebitron’s website. A cookie is a small file which stores certain information about a user’s access device (PC, Tablet, Smartphone etc.) on such device. When such device accesses Vebitron’s server’s website, the server receives such cookies. The server can evaluate the information stored in the cookie by different methods. Cookies enable e.g. personalized advertisements according to the collected user behavior and collecting statistical data of the use of the website. The Users may accept or disable cookies via their browser settings. However, if a user disable cookies he or she may potentially not be able to use all interactive functions of Vebitron’s website. For more information about the processing of personal data via cookies see the section 4 Google Analytics.
  2. Moreover, in accordance with Art. 6 para. 1 sent. 1 point f GDPR, every single web page uses log files, i.e. for every page impression, the access data are saved to the server log. The saved data record contains the following details
    • The date, the time, the file accessed, the status, the request that user’s browser sent to the server, the amount of data transmitted and the webpage from which the user accessed the requested page (referrer) as well as
    • The product and version information of the browser used, user’s operating system and user’s country of origin.
  3. Vebitron uses the log data only in anonymized form (i.e. without any allocation to or indications about user’s person) for statistical analyses, e.g. to find out on which days and at what times the offers of Vebitron’s webpages are most popular and how much data volume is generated on Vebitron’s webpages. Moreover, the log files enable Vebitron to detect possible errors, e.g. faulty links or software bugs. Thus, Vebitron can use the log files for the further development of Vebitron’s webpages. Vebitron never associates the use and page impressions that are stored in the server log with individual persons. Vebitron reserves the right to use data from log files if certain facts give rise to the suspicion that users use Vebitron’s websites and/or services in an unlawful or non contractual way.

4 Google Analytics

In accordance with Art. 6 para. 1 sent. 1 point f GDPR, Vebitron’s website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, text files placed on user’s computer, to help the website analyze how users use the site. The information generated by the cookie about user’s use of the website will normally be transmitted to and stored by Google on servers in the United States.
In accordance with the Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 transfers from a controller or processor in the European Union to organisations in the U.S. that have self-certified their adherence to the EU-U.S. Privacy Shield Framework Principles with the Department of Commerce and have committed to comply with them are allowed. Google has self-certified its adherence to the EU-U.S. Privacy Shield Framework Principles and has committed to comply with them.
In case of activation of the IP anonymization on this website, Google will shorten the IP address beforehand for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. The IP anonymization is active on this website. On behalf of Vebitron Google will use this information for the purpose of evaluating user’s use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website provider.
Google will not associate user’s IP address with any other data held by Google. Users may disable the use of cookies by selecting the appropriate settings on their browser. However, if a user disable cookies he or she may potentially not be able to use all interactive functions of Vebitron’s website. Furthermore user may prevent Google’s collection and use of cookie generated data and data regarding his or her use of the website (incl. his or her IP address) by downloading and installing the browser plug-in available under
https://tools.google.com/dlpage/gaoptout?hl=en-GB


5 Collection and Processing of Personal Data when using Vebitron’s Contact Form

If a user provides Vebitron personal data by using Vebitron’s contact form he expressly gives his consent that Vebitron may store and use this data for the processing of user’s query. He has the right to withdraw his consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Please see also further information on User’s rights in Sec. 8 and about the Period of Data Storage in Sec. 9.


6 Collection and Processing of Personal Data of Newsletter Recipients

If you register for Vebitron’s Newsletter, Vebitron collects, stores and uses the data asked for in the registration form only for the purpose of sending you the newsletter. Moreover, Vebitron stores your IP address in order to be able to prove your consent. With the Newsletter Vebitron informs you about the products and services offered by Vebitron. By subscribing to Vebitron’s newsletter only your email address provided at the registration is being transferred to, and stored at, the MailChimp server in the United States of America. MailChimp is a service offered by The Rocket Science Group LLC with legal seat in the U.S. In accordance with the Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 transfers from a controller or processor in the European Union to organisations in the U.S. that have self-certified their adherence to the EU-U.S. Privacy Shield Framework Principles with the Department of Commerce and have committed to comply with them are allowed. The Rocket Science Group LLC has self-certified its adherence to the EU-U.S. Privacy Shield Framework Principles and has committed to comply with them.
After registration, you receive an email to confirm your membership in the email list. On behalf of Vebitron MailChimp stores and uses your email address for sending of the newsletter only. MailChimp will not transfer your email address.
In Vebitron’s newsletter MailChimp includes single pixel gifs, also called web beacons. Web beacons allow MailChimp to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. MailChimp uses the data from those Web Beacons to create reports about how Vebitron’s email campaign performed and what actions you took. MailChimp provides Vebitron with these reports.
At the bottom of each email newsletter you will find a hyperlink via which you may unsubscribe from the newsletter at any time.
You may also unsubscribe from receiving the Newsletter at any time via a message to Vebitron’s email or postal address as mentioned at the beginning of this Privacy Policy. If you withdraw your consent by unsubscribing, this does not affect the lawfulness of processing based on consent before its withdrawal.
When you unsubscribe from the Newsletter, the personal data which have been retained to make available the newsletter to you will be deleted, provided such deletion does not contradict to a statutory data retention requirement.
If you do not confirm your registration for the Newsletter, Vebitron deletes the respective data after 24 hours from your receipt of the confirmation mail.


7 The recipients or categories of recipients of the personal data

In context with Vebitron’s service providing Vebitron contracts service providers and auxiliary agents such as host providers, web and advertising agencies, IT service providers and the providers as mentioned in sec. 2 and 4 of this Privacy Policy who may have access to user’s personal data. However, these service providers and auxiliary agents except Coinbase are bound by Vebitron’s instructions and contractual agreements regarding their handling of these data. This applies accordingly to service providers and auxiliary agents who have their legal seat outside the EU/EEA.


8 Your Rights

The data subject may according to Articles 15 through 18 GDPR request from Vebitron access to and rectification or erasure of personal data or restriction of processing concerning the data subject. Moreover the data subject has, subject to Art. 20 GDPR, the right to receive the personal data concerning him or her, which he or she has provided to Vebitron, in a structured, commonly used and machine-readable format, and the right to transmit those data to another controller without hindrance from Vebitron. According to Art. 21 para. 1 GDPR, the data subject shall also have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Art. 6 para. 1 sent. 1 GDPR. Vebitron shall comply with the aforementioned requests if and to the extent such compliance is required by the applicable statutory laws.
Requests for access to and rectification or erasure of personal data or restriction of processing may be directed to the email or post address stated at the beginning of this Privacy Policy.
Each data subject has the right to lodge a complaint with a supervisory authority of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes the GDPR.
Where personal data are processed for direct marketing purposes, according to Art. 21 para. 2 GDPR, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.


9 Period of Data Storage

Vebitron processes and stores personal data only for the period, which is required to meet the purpose of processing, or as long and to the extent as statutory laws require Vebitron to process and/or store such data.
If the purpose of processing does not apply anymore and the applicable statutory retention requirement expires, Vebitron will as a matter of routine erase data or restrict the processing of data in accordance with the applicable statutory laws.


10 Amendment of these Privacy Policy

Vebitron reserves the right to amend this Privacy Policy for the purpose of adapting it to technical or legal changes. Therefore, please access this Privacy Policy regularly in order to read up on its latest status. If necessary, Vebitron informs about modifications and asks for consent.


Last updated: 26.10.2018