Introduction
This Privacy Policy explains how 879jili collects, stores, uses and discloses Personal Data in connection with the Website and related services (the Services). It applies to all users worldwide who access the Website or use the Services. By using the Website or the Services, you acknowledge and consent to the practices described in this Policy. If you disagree with any part of this Policy, you must stop using the Website and the Services.
Definitions
- Personal Data means any information relating to an identified or identifiable natural person.
- Processing means any operation or set of operations performed on Personal Data, whether by automated means or not.
- Controller means the natural or legal person who determines the purposes and means of the Processing of Personal Data, alone or jointly with others; for this Policy, that entity is 879jili.
- Processor means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.
- Recipient means a natural or legal person, public authority, agency or other body to which Personal Data is disclosed.
- Consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they signify agreement to the Processing of Personal Data.
- Data Subject means the natural person to whom Personal Data relates.
- Data Protection Officer means the person designated by 879jili to oversee data protection matters.
Categories of Personal Data We Collect
- Identity Data: name, date of birth, government issued identifiers where required for verification.
- Contact Data: address, email address, telephone number.
- Account Data: username, password hash, gender, date of birth where applicable.
- Verification Data: KYC/AML documentation such as government issued ID, utility bills or bank statements as necessary for identity verification.
- Financial Data: payment method details, transaction history, and where applicable the last four digits of a payment instrument.
- Usage and Technical Data: IP address, device type, browser type and version, operating system, language, and information about your interactions with the Website.
- Marketing Data: preferences for receiving communications and interaction with marketing campaigns.
How We Collect Personal Data
- Direct collection: when you provide information through account creation, forms or communications with our staff.
- Automated technologies: through your use of the Website, including cookies and similar technologies to collect usage data.
- From service providers: data we receive from payment processors, identity verification services, hosting and analytics providers, and other professional services we engage.
How We Use Personal Data
- To provide and operate the Services, including account creation, authentication and transaction processing.
- To verify identity and comply with Know Your Customer and Anti Money Laundering obligations.
- To maintain security, protect against fraud and investigate suspicious activity.
- To respond to inquiries, provide customer support and improve the Services.
- To communicate with you about updates, maintenance windows and changes to the Services, subject to your marketing preferences.
- To conduct data analysis and improve user experience and system performance.
Legal Basis for Processing
- Contractual necessity: Processing necessary to provide and administer the Services and fulfill our contractual obligations.
- Legitimate interests: Security, fraud prevention, and analysis to maintain and improve the Services, subject to appropriate safeguards.
- Legal obligations: Compliance with applicable laws and regulatory requirements including KYC/AML and financial reporting.
- Consent: Where required for direct marketing or other processing not essential to the Services.
Sharing and Disclosure of Personal Data
- Service Providers: We may share Personal Data with providers who perform services on our behalf, including hosting, payment processing, identity verification, IT security, analytics, and customer support.
- Legal and Regulatory: We may disclose Personal Data to regulators, law enforcement, or as required by law or court order.
- Business Transfers: In the event of a merger, acquisition or sale of assets, Personal Data may be transferred as part of the transaction, with protections consistent with this Policy.
- Protecting Rights and Safety: We may disclose Personal Data to protect the rights, property or safety of 879jili, our users or others.
International Data Transfers
We may transfer Personal Data to countries outside your country of residence, including jurisdictions that may not have the same level of data protection. In such cases we implement safeguards to protect your data, such as contractual clauses and other legally recognized transfer mechanisms, and we assess the adequacy of protection on a case-by-case basis.
Your Rights as a Data Subject
- Right of access: You may request copies of your Personal Data held by us.
- Right to rectification: You may request correction of inaccurate or incomplete data.
- Right to erasure: You may request deletion of Personal Data where applicable, subject to legal obligations.
- Right to restrict processing: You may limit Processing under certain circumstances.
- Right to data portability: You may request transfer of your Personal Data to another organization or to you in a structured, commonly used format where applicable.
- Right to withdraw consent: You may withdraw consent for Processing that is based on consent.
- Right to object: You may object to Processing based on legitimate interests or direct marketing.
Requests should be directed to [email protected]. We will respond within one month of receipt, and in complex cases the period may be extended with notice.
Data Retention and Deletion
We retain Personal Data only for as long as necessary to satisfy the purposes for which it was collected, or to comply with legal obligations. Typical retention periods include the duration of the user relationship plus a period to meet regulatory and legal requirements (minimum seven years for AML/accounting purposes in some jurisdictions). After the retention period expires, data will be securely deleted or anonymized.
Data Security
We implement technical and organizational measures to protect Personal Data from unauthorized access, alteration, disclosure or destruction. These measures include encryption in transit, access controls, anomaly monitoring, regular security assessments and vendor due diligence. Access to Personal Data is restricted to personnel who have a legitimate business need.
Your Rights and Marketing Preferences
You may opt out of promotional communications at any time by using the unsubscribe mechanism or by contacting us. Marketing data will be processed based on your consent or our legitimate interests, as applicable. We will not share Personal Data for marketing purposes with third parties without your consent unless necessary for the provision of Services or as required by law.
Cookies
We use cookies and similar technologies to operate and improve the Website. Types of cookies include essential cookies (necessary for the operation of the Website), functional cookies (provide enhanced features), performance cookies (collect usage data for improvement) and marketing cookies (deliver relevant offers). You may adjust cookie preferences through your browser settings and delete stored cookies periodically. Some cookies are strictly necessary for the execution of transactions or authentication and cannot be disabled.
Minors
The Services are not directed at individuals under the age of 18 or the applicable legal minimum age. If we learn that a minor has provided Personal Data, we will take steps to remove the information and terminate access.
Access, Correction and Deletion Requests
To exercise any of the rights above, contact [email protected]. We will verify your identity prior to fulfilling requests and will respond within one month, with possible extensions where permitted by law.
Security Reviews and Verification
We may perform security reviews to validate user information and verify transactions for compliance with this Policy and applicable law. By using the Services you authorize such verifications, including cross-checks with third-party databases as needed to protect against fraud and money laundering.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time. We will publish the latest version on the Website and indicate the effective date of the update. Material changes will be communicated through appropriate channels. Your continued use of the Website after updates constitutes acceptance of the revised Policy.
Data Controller and Processors
The data controller for Personal Data under this Policy is 879jili. We may engage third-party processors to perform processing on our behalf, subject to written contracts that require appropriate data protection safeguards. For questions about processing or to exercise rights, contact [email protected].
Complaint Mechanism
If you have concerns about our handling of Personal Data, you may submit a complaint to the local data protection supervisory authority in your jurisdiction, or contact us for assistance in identifying the appropriate authority.