This Privacy Policy of Rhino Digital Inc. (“Rhino Digital,” “us,” “we,” and “our”) describes the information we collect about you when you access our website or web application, enter into agreements with us, use our services and products, send us communications, or otherwise engage with us, and what we do with such information. Any references to Rhino Digital in this Privacy Policy also refer to its wholly owned subsidiaries. This Privacy Policy covers all of our services and products and all methods by which you may access our website or web application.
By opening an account with us and utilizing our services, products, website, and web application, you agree to the terms of our Privacy Policy. If you do not agree to the terms of our Privacy Policy, you cannot use our services or products and should not access our website or web application.
We understand that privacy is an important issue to you, and we respect the privacy of our consumers, clients, and users. This means that we strive to collect only the Personal Information we need. We aim to protect the security and confidentiality of Personal Information about you that we acquire.
Under the law you have the right to limit some, but not all, sharing of your Personal Information. The law also requires us to disclose to you how we collect, share, and protect your Personal Information.
Please see our Privacy Notice for additional information about how we use and share information we obtain to provide financial services and products.
Personal Information We Collect:
For the purposes of this Privacy Policy, Personal Information is information that can reasonably identify, relate to, describe, be associated with, or reasonably be associated with a particular individual or household. Personal Information also includes information that may be classified as “Personal Data” or “Personally Identifiable Information” in some jurisdictions. This Privacy Policy does not apply to anonymized data, as it cannot be used to identify you.
We may collect, store, use, and transfer the following types of Personal Information:
Other Information We Collect
We also collect other information in the form of aggregated statistics that do not uniquely identify you as an individual. This information is referred to as “de-identified information.” We collect de-identified information when you interact with us and use our services and products. Examples may include traffic visits on the website and web application, information on the links you click, the features of our website that you use, and the types of information you upload. We may share de-identified information with our advertising and marketing agents to evaluate the effectiveness of our marketing programs. Additionally, we may use this information to analyze your website usage and for other research that helps us improve our services and products.
How We Collect Your Personal Information
We collect your Personal Information from the following sources:
Why We Collect and Use Your Personal Information
We only collect and use your Personal Information, as required or permitted by applicable law, for the following purposes:
We will not use your Personal Information for purposes other than those purposes we have disclosed to you without your permission. If we need to use your Personal Information for an unrelated, new, or additional purpose, we will notify you and obtain your consent to use it for such unrelated, new, or additional purposes.
Legal Basis for Collecting and Using Your Personal Information
We rely on the following legal bases, as required by applicable law, to collect and use your Personal Information:
Sharing Your Personal Information
We do not disclose or sell your Personal Information to any third parties, except to those who require access to the data to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. This may include but is not limited to, any obligations of Rhino Digital under the USA PATRIOT Act, and to facilitate the execution of our clients’ cryptocurrency transactions in the ordinary course of business.
We transfer, disclose, or allow access to your Personal Information to affiliated companies and third parties for the purposes described below:
Other circumstances under which we may disclose your Personal Information include to:
If an affiliate company or a third party needs access to certain Personal Information to carry out certain functions on our behalf, they do so under our instructions. All affiliates and third parties with whom we share Personal Information have their own privacy policies; however, they are expected to protect this information in a manner that aligns with the protocols described in this Privacy Policy. We do not share Personal Information with affiliates for their own benefit, unless you have given us your consent. Additionally, we do not share your Personal Information with third parties for their benefit.
Opting Out of Sharing Your Personal Information
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 from 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 authorization. If you choose to so limit the use of your Personal Information, certain features or Rhino Digital services may not be available to you.
Third-Party Websites
We may have links to unaffiliated third-party websites on our website. These third-party websites have their own privacy policies. We have no involvement with their policies and are not responsible for their practices. You are encouraged to review the privacy policies of all third-party websites you visit.
Marketing Communication
We, or our service providers on our behalf, may use your Personal Information to send you marketing and promotional communication that we believe may enhance your experience with our services or products, or may be of interest to you. If you do not want to receive marketing and promotional communication from us, you can opt-out at any time by contacting us at compliance@rhinobitcoin.com, or by unsubscribing via the links provided in the marketing emails.
Sale of Your Personal Information
Rhino does not sell your Personal Information to any third parties.
Personal Information of Minors
Our services and products are not intended for individuals under the age of eighteen (18). We do not knowingly collect and use Personal Information related to minors.
Use of Cookies
Cookies are small text files sent from a site to the hard drive of a user's device to store bits of information related to that user or device. First-party cookies are put on your device directly by our website, which allows us to collect analytical data and provide other useful functions that create a good user experience. Third-party cookies are placed on your device by a third party (e.g., advertiser or analytic system). The third parties who serve cookies on our site may link your name or email address to other information they collect, which may include past purchases made offline or online, or your online usage information.
Rhino Digital uses cookies to provide better service, to facilitate use of our website, to track usage of our website, to collect data, and to address certain security issues. When you access our website, we send the cookies to your computer or phone. Your computer or phone stores the cookie in a file located inside your web browser. The cookies help Rhino Digital keep track of your visits to our website and your activity on our website to understand how you interact with us.
We may link the information collected by cookies with other information we collect from you pursuant to this Privacy Policy and use the combined information as set forth herein.
We use the following types of cookies:
Functional Cookies allow our website to provide enhanced functionality. For example, we use these cookies to notify you of account updates, notifications, and reminders. You may refuse to accept these cookies; however, this may affect access to certain parts of our website. Additionally, you may not be able to take advantage of personalized features.
Performance Cookies collect information about how you use our website, for example, which pages you visited and which links you clicked on. The information collected is aggregated and cannot be used to identify you.
Marketing Cookies may be set on our website by our advertising and marketing service providers. They are used to track your online activities and help us provide relevant advertising, links, or other information about our services and products to users visiting other websites after visiting our website.
Name of Cookie/Identifier
What does the cookie generally do (e.g., website function and administration, analytics, marketing)?
Is it a 1st or 3rd party cookie and what is the name of the party providing it?
What type of cookie is it (persistent or session)?
What is the duration of the cookie on the website (if not cleared by the user)?
You can generally activate or later deactivate the use of cookies through a functionality built into your web browser. If you want to learn more about cookies, or how to control, disable or delete them, please visit https://www.aboutcookies.org for detailed guidance. The following link explains how Google uses data when you use its partners’ websites and applications. Certain third-party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing.
Security
Rhino Digital strives to ensure that our systems are secure and that they meet industry standards. We seek to protect non-public Personal Information that is provided to Rhino Digital by third parties and you by implementing physical and electronic safeguards. Where we believe appropriate, we employ firewalls, intrusion prevention, encryption technology, user authentication systems (i.e. passwords and personal identification numbers) and access control mechanisms to control access to systems and data. Rhino Digital endeavors to engage third-party service providers that have security and confidentiality policies, if such third-party service providers have access to our client’s Personal Information. We instruct our employees to use strict standards of care in handling the personal financial information of clients. As a general policy our staff will not discuss or disclose information regarding an account except with authorized personnel of our service providers or as required by applicable law and regulatory requirements law or pursuant to regulatory request and/or authority.
Despite our efforts to protect the security of your information, no security system is always effective, and we cannot guarantee that our systems will be completely secure.
How Long We Keep Information
Your Privacy Rights
You can access, correct, or modify the information you provided to us by editing your profile and adjusting your account settings.
Note that we may refuse to grant your requests in whole or in part as permitted by applicable law.
If you close your Rhino Digital account, we will mark your account in our database as “Closed,” but will keep your account information in our database for a period of time described in “How Long We Keep InformationRetention”. This is necessary to deter fraud by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your Personal Information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.
You can manage your privacy settings and other account features here. If you change your settings it may take some time for your choices to be fully reflected throughout our systems. Depending on the settings you've adjusted, you may also notice changes in your Rhino experience or limitations in your ability to access certain features.
Rhino adheres to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising (also referred to as “interest-based advertising”) and respects the DAA’s consumer choice tool for you to opt out of interest-based advertising at https://optout.aboutads.info/.
European Union and UK
(This section applies to European Union (EU) and UK Residents only)
The EU and UK General Data Protection Regulation (GDPR) allows individuals citizens of or residing in the United Kingdom and the European Union, certain rights over their Personal Information. To exercise these rights, please contact us compliance@rhinobitcoin.com. These rights include:
Information We May Need from You
We may need to request specific information from you (e.g. name and email address) to help us confirm your identity and verify your request. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it, and that your Personal Information is not deleted at the request of anyone but you. We may also contact you to ask you for further information in relation to your request.
Time to Respond to Your Requests
We try to respond to all legitimate and verifiable requests within one calendar month. We may request an extension of up to two months, and we will inform you of why an extension occurs.
If you have an account with us, we may deliver our response to that account. If you do not have an account with us, we will deliver our response by mail or electronically. If we cannot comply with your request, we will provide a detailed explanation of why we cannot comply.
We reserve the right to deny your request if it is malicious in nature or for legal reasons.
Fees
You will usually not have to pay a fee to exercise any rights listed above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may refuse to comply with your request under these circumstances.
In addition to the rights listed above, you also have the right to lodge a complaint with your local Supervisory Authority if you believe that our processing of your Personal Information does not comply with the GDPR. You can find your data protection regulator here. You also have the right to make a complaint to the Information Commissioner’s Office (ICO):
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk
We would appreciate the chance to deal with your concerns, so please contact us compliance@rhinobitcoin.com if you have any issues or complaints with our processing of your Personal Information.
California (CCPA); Colorado (CPA); Virginia (VCDPA) and other state privacy rights
(This section applies to California, Colorado, and Virginia - and other states with privacy rights regulations - Residents only)
The CCPA, the CPA, and the VCDPA, and other US state laws, afford their state residents specific rights over their Personal Information. To exercise these rights, please contact us at compliance@rhinobitcoin.com. These rights include:
Information We May Need from You
We may need to request specific information from you (e.g. name and email address) to help us confirm your identity and verify your request. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it, and that your Personal Information is not deleted at the request of anyone but you unless the individual is your authorized agent. We may also contact you to ask you for further information in relation to your request.
Time to Respond to Your Requests
CCPA: We endeavor to address valid and verifiable requests within 45 days. An additional 45-day extension may be requested if necessary, and notification will be provided.
CPA: Our objective is to respond to all legitimate and verifiable requests within 45 days. We retain the option to request a 45-day extension and will inform you accordingly.
VCDPA: We strive to fulfill legitimate and verifiable requests within 45 days. If needed, an additional 45-day extension may be requested, and you will be notified of such a request.
If you have an account with us, we may deliver our response to that account. If you do not have an account with us, we will deliver our response by mail or electronically. If we cannot comply with your request, we will provide a detailed explanation of why we cannot comply.
Please note, we are not required to action requests to access your Personal Information more than twice in a 12-month period.
Please note that we can refuse a DSAR if the personal information is needed to fulfill a contractual obligation between us and the requestor or if we are legally obligated to retain the data.
Fees
You will usually not have to pay a fee to exercise any rights listed above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may refuse to comply with your request under these circumstances.
Authorized Agents - CCPA
You can authorize a designated agent to exercise your rights on your behalf. To authorize a designated agent please contact us compliance@rhinobitcoin.com.
California Shine the Light (California Civil Code 1798.83)
California residents, who have an established business relationship with us, may request that we disclose the categories of Personal Information we share with third parties, if any, for the third parties’ direct marketing purposes, and the list of third parties to whom the Personal Information was shared in the preceding calendar. To request this disclosure, please contact us compliance@rhinobitcoin.com. Please note, the request is free of charge and we are required to respond to one request per California resident each year.
California Financial Information Privacy Act
The California Financial Information Privacy Act limits what we can do with your financial information and gives you rights to limit our sharing of your financial information. Under the California Financial Information Privacy Act, California residents have the right to: receive notice and opt-in to us sharing non-public Personal Information with non-affiliated third parties; receive notice and opt-out of sharing non-public Personal Information with affiliates; and opt-out of Personal Information sharing resulting from joint-marketing agreements with non-affiliated third parties to market financial products and services.
We do not share your information with affiliates and non-affiliated third parties, except for certain business purposes (e.g., to service your accounts), to market our products and services, as permitted by law, or with your consent. You can access our Privacy Notice for information about our practices in accordance with the California Financial Privacy Act. Please contact us compliance@rhinobitcoin.com to opt-in to, or opt-out of, sharing your nonpublic Personal Information.
California “Do Not Track” Policy
California law requires us to inform you how we respond to web browser Do Not Track (“DNT”) signals. Because no industry or legal standard exists for recognizing or honoring DNT signals, we do not respond to them at this time. This Privacy Policy is subject to change as the privacy community and industry develop best practices for responding to DNT signals.
Vermont
(This section applies to Vermont Residents only)
Vermont Financial Privacy Act
The Vermont Financial Privacy Act limits what we can do with your financial information and gives you rights to limit our sharing of your financial information. Under the Vermont Financial Privacy Act, Vermont residents have the right to receive notice and opt-in to sharing non-public Personal Information with non-affiliated third parties. Additionally, residents must consent to us sharing information regarding credit worthiness.
We do not share your information with affiliates and non-affiliated third parties, except for certain business purposes (e.g., to service your accounts), to market our products and services, as permitted by law, or with your consent. Additionally, we will not disclose credit information about you with our affiliates or non-affiliated third parties, except as required or permitted by law. You can access our Privacy Notice for information about our practices in accordance with the Vermont Financial Privacy Act. Please contact us at compliance@rhinobitcoin.com. to opt-in to, or opt-out of, sharing your nonpublic Personal Information.
When Do We Store, Transfer or Process Your Personal Information Internationally?
Rhino Digital has committed to meeting the requirements of local data protection laws, including EU law, to the extent required. Please be aware that your Personal Information will be transferred to, processed, and stored in our data servers located within the United States. You consent to the transfer of your information, including Personal Information, to the U.S. as set forth in this Privacy Policy by visiting our site or using our service.
Changes to Rhino Digital’s Privacy Policy
This Privacy Policy is available on our website at http://rhinobitcoin.com/privacy . Rhino Digital reserves the right to make changes to this Privacy Policy. You should review our Privacy Policy frequently. If we make material changes to our Privacy Policy, our revised Privacy Policy will be posted on our website and it will either be noted on our website that material changes have been made or we will notify our clients by email. The date of the most recent update to our Privacy Policy will be set forth at the end of this Privacy Policy.
How to Get in Touch with Rhino Digital
If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you should first contact us by emailing us at compliance@rhinobitcoin.com or by calling us at 1.888.854.3824.
If you would like to submit a complaint about our use of your Personal Information or response to your requests regarding your Personal Information, you may contact us at compliance@rhinobitcoin.com.
Last Updated: January 8, 2024