BASISPOINT PRIVACY POLICY
1. Introduction
This Privacy Policy explains how BasisPoint (“BasisPoint”, “we”, “us” or “our”) collects, uses, stores, shares and otherwise processes personal data when you:
- visit the BasisPoint website;
- access or use the BasisPoint application;
- create or manage an account;
- subscribe to or purchase a service;
- communicate with us;
- connect an exchange account, wallet, protocol account or other third-party service;
- use our APIs, data feeds, research tools, analytics, alerts or other functionality; or
- otherwise interact with a service made available under the BasisPoint name.
The websites, applications, software, APIs, content and related services covered by this Privacy Policy are collectively referred to as the “Platform”.
“Personal data” means information that identifies you or can reasonably be linked to you. It may also be described as personal information under applicable law.
By using the Platform, you acknowledge that your personal data will be handled as described in this Privacy Policy.
This Privacy Policy does not form part of the BasisPoint Terms of Use.
2. Who is responsible for your personal data
BasisPoint is responsible for determining why and how personal data collected through the generally available Platform is processed.
Depending on the context, BasisPoint may act as:
- a data controller or business responsible for determining how personal data is used;
- a joint controller with another organisation; or
- a processor or service provider processing personal data on behalf of an institutional or commercial customer.
Where we process personal data on behalf of an organisational customer, the customer may be primarily responsible for providing you with information about that processing and responding to your data-protection requests.
Questions about this Privacy Policy or our processing of personal data may be submitted through the contact details or support channels displayed on the Platform.
3. Personal data we collect
The personal data we collect depends on how you interact with the Platform and which features you use.
3.1 Account and identity information
We may collect:
- your name;
- username;
- email address;
- telephone number;
- password or authentication information;
- account identifier;
- profile information;
- job title;
- employer or organisation;
- professional role;
- country or general location;
- communication preferences;
- account type;
- subscription tier; and
- information used to confirm your authority to act for an organisation.
We do not ordinarily have access to your complete password where authentication is managed securely by us or by an authentication provider.
3.2 Business and professional information
Where you use the Platform in a professional or institutional capacity, we may collect:
- organisation name;
- business contact details;
- industry;
- role and responsibilities;
- team membership;
- business requirements;
- areas of interest;
- product requirements;
- expected Platform usage;
- investment or treasury mandate information supplied by you;
- regulatory or professional classification;
- billing contacts; and
- information provided during onboarding or sales discussions.
3.3 Subscription and payment information
If you purchase a subscription or paid service, we may collect:
- billing name;
- billing address;
- invoice information;
- tax information;
- payment status;
- subscription history;
- transaction identifiers;
- partial payment-card information;
- payment-provider information; and
- records of refunds, disputes or failed payments.
Payment information may be collected and processed directly by a third-party payment provider. We may not receive or store your complete payment-card number or security code.
3.4 Connected-account and integration information
If you connect an exchange, wallet, protocol, blockchain address, API credential or other third-party account, we may collect or access:
- the name of the connected service;
- account identifiers;
- public wallet addresses;
- public blockchain information;
- balances;
- positions;
- transaction history;
- orders;
- trade history;
- funding payments;
- portfolio holdings;
- collateral information;
- permissions granted to the Platform;
- connection status;
- API metadata;
- authentication tokens;
- technical credentials; and
- other information made available through the integration.
The information available to us depends on the permissions you grant.
You should use read-only permissions where execution, withdrawal or transfer permissions are not required.
We will not ask you to provide private keys or wallet seed phrases. You should never disclose a private key or seed phrase through the Platform, through a support message or to anyone claiming to represent BasisPoint.
3.5 Research, strategy and portfolio information
When you use research, analytics, backtesting, portfolio, treasury, strategy or agent-assisted features, we may collect:
- assets and markets viewed;
- searches and filters;
- saved screens;
- watchlists;
- alerts;
- selected exchanges or protocols;
- portfolio configurations;
- backtesting rules;
- strategy parameters;
- hedge parameters;
- risk limits;
- model settings;
- reports;
- exported information;
- prompts submitted to automated tools;
- workflow configurations; and
- other information you enter into or generate through the Platform.
This information may reveal your trading, investment, research or commercial interests.
You are responsible for ensuring that you have authority to provide information relating to another person, organisation, account or portfolio.
3.6 Communications and support information
We may collect information when you:
- contact support;
- submit an enquiry;
- report an error;
- request a demonstration;
- provide feedback;
- participate in a survey;
- communicate with us through email or messaging services;
- attend a meeting or call; or
- otherwise communicate with us.
This may include:
- your contact details;
- the contents of your communications;
- attachments;
- support history;
- meeting notes;
- call recordings where permitted and disclosed;
- diagnostic information;
- account information; and
- other information you choose to provide.
3.7 Device, usage and technical information
When you access the Platform, we may automatically collect:
- internet protocol address;
- browser type and version;
- device type;
- operating system;
- device identifiers;
- language settings;
- time zone;
- approximate location derived from an IP address;
- referring and exit pages;
- pages, screens and features accessed;
- links and buttons selected;
- session duration;
- timestamps;
- application events;
- error reports;
- crash data;
- performance information;
- network information;
- authentication activity;
- API requests;
- log files; and
- security-related information.
We may use this information to operate, secure, analyse and improve the Platform.
3.8 Cookies and similar technologies
We may use cookies, local storage, software development kits, pixels, tags and similar technologies to:
- keep the Platform functioning;
- maintain sessions;
- remember preferences;
- authenticate users;
- prevent fraud and abuse;
- measure traffic and performance;
- understand how features are used;
- diagnose errors;
- improve the Platform; and
- measure communications or marketing where permitted.
More information may be provided through our cookie notice or cookie-preference tool.
Where required by applicable law, we will ask for consent before using non-essential cookies or similar technologies.
You can manage available choices through the cookie-preference tool and through your browser or device settings. Blocking certain technologies may affect Platform functionality.
3.9 Public blockchain information
Blockchain networks generally make certain information publicly available. This may include:
- wallet addresses;
- transaction identifiers;
- transaction history;
- asset balances;
- smart-contract interactions; and
- timestamps.
We may obtain this information directly from public blockchains, blockchain nodes, explorers, analytics providers or protocols.
Public blockchain records may remain permanently available on the relevant network. We cannot alter or delete data recorded on a public blockchain.
3.10 Information from third parties
We may receive personal data from:
- authentication providers;
- payment providers;
- exchanges;
- wallet providers;
- protocols;
- blockchain analytics services;
- market-data providers;
- business partners;
- referral partners;
- institutional customers;
- analytics providers;
- security and fraud-prevention providers;
- communication providers;
- public websites;
- public databases;
- professional networking services; and
- publicly accessible blockchain networks.
The information received depends on the relevant third party, your settings and the permissions you provide.
3.11 Information we derive
We may derive information from the data available to us, including:
- account-security assessments;
- user preferences;
- likely areas of interest;
- feature-usage patterns;
- engagement information;
- account or organisational relationships;
- risk or fraud indicators;
- technical-performance classifications; and
- aggregated statistics.
Derived information will be treated as personal data where it identifies or can reasonably be linked to an individual.
3.12 Sensitive personal data
The Platform is not intended for the collection of highly sensitive personal data, such as:
- health or medical information;
- biometric identifiers;
- religious or philosophical beliefs;
- political opinions;
- trade-union membership;
- information about sexual life or orientation; or
- complete government-issued identity numbers,
unless a specific feature expressly requests that information and appropriate notices and safeguards are provided.
You should not submit sensitive personal data through general Platform fields, prompts or support channels.
4. How we use personal data
We may use personal data for the following purposes.
4.1 Providing the Platform
We may process personal data to:
- create and administer accounts;
- authenticate users;
- deliver Platform features;
- provide market data, research and analytics;
- generate requested reports and outputs;
- save settings and preferences;
- operate watchlists and alerts;
- process API requests;
- connect permitted third-party services;
- maintain organisational workspaces;
- provide subscriptions;
- process payments;
- deliver customer support; and
- otherwise perform services requested by you.
4.2 Operating connected accounts
Where you connect a third-party account, we may process information to:
- establish and maintain the connection;
- retrieve data authorised by you;
- display balances, positions or transaction information;
- perform calculations;
- generate analytics;
- monitor connection status;
- identify synchronisation errors; and
- carry out instructions that you expressly submit through an enabled feature.
We will process connected-account information only to the extent reasonably necessary to provide the relevant functionality, comply with law and protect the Platform.
4.3 Personalising the Platform
We may use personal data to:
- remember your preferences;
- customise dashboards;
- prioritise relevant modules;
- display saved markets or assets;
- tailor documentation and onboarding;
- provide relevant alerts; and
- improve your experience.
4.4 Communicating with you
We may use personal data to:
- respond to enquiries;
- provide support;
- send service notices;
- notify you about account activity;
- communicate security issues;
- provide invoices and billing notices;
- inform you about changes to the Platform or applicable terms;
- request feedback; and
- deliver other operational communications.
Operational and security communications may be sent even where you have opted out of marketing communications.
4.5 Improving and developing the Platform
We may use personal data to:
- understand how the Platform is used;
- assess feature performance;
- diagnose problems;
- conduct research and analysis;
- develop new features;
- improve user interfaces;
- test software;
- monitor data quality;
- improve models and algorithms;
- evaluate product demand; and
- create aggregated statistics.
Where reasonably possible, we use aggregated, de-identified or pseudonymised information for these purposes.
We do not use private customer data to train general-purpose artificial-intelligence models unless this is disclosed to you or separately agreed.
4.6 Security, fraud prevention and misuse detection
We may process personal data to:
- protect accounts;
- detect unauthorised access;
- prevent fraud;
- detect malicious activity;
- investigate suspected misuse;
- enforce rate limits;
- prevent sanctions evasion;
- protect our systems;
- identify software vulnerabilities;
- maintain audit logs;
- enforce our Terms of Use; and
- protect users, third parties and the Platform.
4.7 Compliance and legal purposes
We may process personal data to:
- comply with applicable laws;
- respond to lawful requests;
- establish, exercise or defend legal claims;
- conduct audits;
- maintain business records;
- enforce agreements;
- investigate complaints;
- protect legal rights;
- comply with tax, accounting or reporting obligations;
- conduct sanctions or restricted-person screening where appropriate; and
- cooperate with courts, regulators, law-enforcement bodies or other competent authorities.
4.8 Marketing
Subject to applicable law and your preferences, we may use contact and engagement information to:
- provide information about BasisPoint;
- send product updates;
- invite you to events;
- provide research or newsletters;
- inform you about new features;
- follow up on enquiries; and
- promote services that may be relevant to you.
You can unsubscribe from marketing emails by using the unsubscribe link in the relevant message or by contacting us.
Opting out of marketing does not prevent us from sending operational, billing, contractual or security communications.
4.9 Business transactions
We may process and disclose personal data in connection with:
- an investment;
- financing;
- reorganisation;
- merger;
- acquisition;
- asset sale;
- joint venture;
- insolvency;
- due-diligence process; or
- transfer of all or part of the Platform or related business.
Where appropriate, recipients will be required to protect the information and use it only for the relevant transaction.
5. Legal bases for processing
Where applicable data-protection law requires us to identify a legal basis, we may rely on one or more of the following:
5.1 Performance of a contract
We may process personal data where necessary to:
- create and administer your account;
- provide requested Platform functionality;
- process a subscription;
- deliver support;
- operate a connected service;
- fulfil an order; or
- otherwise perform an agreement with you.
5.2 Legitimate interests
We may process personal data where necessary for our legitimate interests or those of another person, provided those interests are not overridden by your rights.
These interests may include:
- operating and improving the Platform;
- protecting the Platform and its users;
- preventing fraud and abuse;
- understanding Platform usage;
- maintaining business relationships;
- communicating with professional and institutional users;
- developing products;
- enforcing agreements;
- protecting legal rights; and
- maintaining network and information security.
Where required, we assess whether the processing is necessary and proportionate and whether your interests or rights override the relevant legitimate interest.
5.3 Consent
We may rely on consent for activities including:
- certain cookies and similar technologies;
- particular marketing communications;
- optional integrations;
- recording certain communications; or
- other processing where consent is appropriate or required.
You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before consent was withdrawn.
5.4 Compliance with legal obligations
We may process personal data where necessary to comply with laws, court orders, regulatory obligations, tax requirements, accounting rules or lawful requests.
5.5 Protection of rights and safety
Where recognised by applicable law, we may process information where necessary to protect the vital interests, safety, property or legal rights of an individual, BasisPoint or another organisation.
5.6 Other lawful bases
We may rely on another legal basis where permitted by applicable law. Where required, we will provide additional information about that basis.
6. When we share personal data
We do not disclose personal data except as described in this Privacy Policy, at your direction or as otherwise permitted by law.
6.1 Service providers
We may share personal data with service providers that support:
- cloud hosting;
- data storage;
- content delivery;
- authentication;
- database management;
- software development;
- application monitoring;
- analytics;
- customer support;
- communications;
- email delivery;
- payment processing;
- accounting;
- security;
- fraud prevention;
- compliance;
- document management; and
- professional advice.
Service providers are permitted to process personal data only for agreed purposes and subject to appropriate contractual and confidentiality obligations.
6.2 Connected services
Where you direct us to connect the Platform to an exchange, wallet, protocol, communication service or other third party, we may share information necessary to:
- authenticate the connection;
- request authorised data;
- submit an instruction;
- maintain the integration; and
- provide the requested functionality.
Your use of the third-party service is also governed by its own terms and privacy policy.
6.3 Organisational customers and administrators
If you use the Platform through an organisation, we may share information with that organisation and its authorised administrators, including:
- account details;
- workspace membership;
- usage information;
- subscription information;
- security events;
- reports;
- saved content; and
- information generated through the organisational account.
Organisational administrators may be able to access, restrict, export or delete information associated with the organisation’s workspace.
6.4 Professional advisers
We may share information with lawyers, accountants, auditors, insurers, consultants and other professional advisers where reasonably necessary to obtain advice, protect our interests or comply with obligations.
6.5 Authorities and legal recipients
We may disclose personal data where we reasonably believe disclosure is necessary to:
- comply with law;
- respond to legal proceedings;
- respond to a lawful government request;
- protect rights or safety;
- investigate fraud, security issues or unlawful activity;
- enforce our agreements; or
- establish, exercise or defend legal claims.
6.6 Business transaction recipients
Personal data may be disclosed to prospective or actual investors, purchasers, sellers, lenders, advisers or transaction counterparties in connection with a corporate or business transaction.
6.7 With your direction or consent
We may share information with another person where you direct us to do so or provide consent.
7. Sale and targeted advertising
We do not sell personal data for money.
We do not use personal data for cross-context behavioural advertising unless this is disclosed through the Platform and any consent or opt-out mechanism required by applicable law is provided.
If our practices change, we will update this Privacy Policy and provide any required choices before applying the change to your personal data.
8. Aggregated and de-identified information
We may aggregate or de-identify information so that it no longer reasonably identifies an individual.
We may use and disclose aggregated or de-identified information for:
- research;
- analytics;
- benchmarking;
- product development;
- security;
- business reporting;
- marketing;
- market analysis; and
- other lawful purposes.
We will not attempt to re-identify information that has been properly de-identified, except where necessary to test or validate the de-identification process or where otherwise permitted by law.
9. Artificial intelligence and automated processing
The Platform may use artificial intelligence, machine learning, statistical models and automated systems to:
- generate analytics;
- classify data;
- summarise information;
- detect technical issues;
- identify security risks;
- improve search or recommendations;
- assist support; and
- automate user-requested workflows.
Automated analytical outputs may be based partly on personal data, such as your account settings, connected-account information, saved preferences or prompts.
Unless we expressly state otherwise, we do not use automated processing to make decisions about you that produce legal or similarly significant effects without appropriate human involvement.
Where applicable law provides rights concerning solely automated decision-making, you may contact us to request information, human review or another available remedy.
10. International data transfers
The Platform may be accessed globally, and our service providers, infrastructure and personnel may be located in different countries.
As a result, personal data may be transferred to, stored in or accessed from a country other than the country in which you are located.
Data-protection laws may differ between countries.
Where required by applicable law, we use recognised safeguards for international transfers, which may include:
- adequacy decisions;
- approved contractual clauses;
- data-processing agreements;
- transfer-risk assessments;
- supplementary technical and organisational measures; and
- another legally recognised transfer mechanism.
You may contact us for further information about safeguards relevant to your personal data.
11. Data retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.
The appropriate retention period depends on factors including:
- the nature and sensitivity of the information;
- the duration of your account or subscription;
- the purposes for which the information was collected;
- whether the information is required to provide the Platform;
- security and fraud-prevention requirements;
- contractual obligations;
- applicable limitation periods;
- legal, regulatory, tax and accounting requirements;
- dispute-resolution needs; and
- whether retention is necessary to establish, exercise or defend legal claims.
Account information may generally be retained while your account remains active and for a reasonable period after closure.
Billing, transaction and contractual records may be retained for longer periods where required for legal, tax, audit or accounting purposes.
Security records and technical logs may be retained for a period appropriate to investigate incidents, maintain Platform integrity and prevent abuse.
Backup copies may remain for a limited period after information is removed from active systems.
We may retain aggregated or properly de-identified information indefinitely where it no longer identifies you.
Public blockchain information may remain permanently available through the relevant blockchain and cannot be erased or modified by us.
12. Data security
We use administrative, technical and organisational measures designed to protect personal data against:
- unauthorised access;
- unlawful processing;
- accidental loss;
- alteration;
- destruction;
- disclosure; and
- misuse.
Measures may include:
- access controls;
- authentication controls;
- encryption in transit;
- encryption at rest where appropriate;
- network and system monitoring;
- logging;
- vulnerability management;
- backups;
- staff and contractor confidentiality obligations;
- restricted production access;
- incident-response procedures; and
- service-provider assessments.
No method of transmission, storage or processing is completely secure. We cannot guarantee absolute security.
You are responsible for:
- protecting your password and authentication credentials;
- enabling available security features;
- maintaining the security of your devices;
- reviewing connected-account permissions;
- using read-only API permissions where appropriate;
- revoking credentials that are no longer required; and
- notifying us promptly of suspected unauthorised access.
Do not send private keys, seed phrases or unnecessary confidential information through the Platform or support channels.
13. Data incidents
If we identify a personal-data incident, we may take steps to:
- contain and investigate the incident;
- protect affected systems;
- assess the potential impact;
- notify service providers or authorities;
- notify affected individuals where appropriate or legally required; and
- reduce the likelihood of recurrence.
Communications concerning an incident may be sent using the contact information associated with your account.
14. Your privacy rights
Depending on your location and applicable law, you may have some or all of the following rights:
- Access: request confirmation of whether we process your personal data and obtain a copy.
- Correction: request correction of inaccurate or incomplete personal data.
- Deletion: request deletion of personal data in certain circumstances.
- Restriction: request that we restrict certain processing.
- Objection: object to processing based on legitimate interests or to direct marketing.
- Portability: request certain personal data in a structured, commonly used and machine-readable format.
- Withdraw consent: withdraw consent where processing is based on consent.
- Opt out of marketing: stop receiving promotional communications.
- Opt out of certain advertising or profiling: exercise applicable choices concerning targeted advertising, sale, sharing or profiling.
- Automated decisions: request information about or review of certain automated decisions.
- Appeal: appeal a decision concerning a privacy request where applicable.
- Complaint: submit a complaint to an appropriate privacy or data-protection authority.
- Non-discrimination: not receive unlawful discriminatory treatment for exercising a privacy right.
These rights are not absolute. A request may be refused or limited where permitted by law, including where processing is necessary to:
- comply with a legal obligation;
- protect another person’s rights;
- establish, exercise or defend legal claims;
- maintain security;
- prevent fraud; or
- complete a transaction requested by you.
Right to object
Where applicable, you may object to processing based on legitimate interests.
You may object to direct marketing at any time. Where you object to direct marketing, we will stop using your personal data for that purpose.
15. Exercising your rights
You may submit a privacy request through the contact details or support channels displayed on the Platform.
Your request should describe:
- the right you wish to exercise;
- the personal data concerned;
- the account or email address involved; and
- any information that may help us locate the relevant records.
We may need to verify your identity before completing a request. We will request only information reasonably necessary for verification.
You may be permitted to use an authorised agent. We may request evidence of the agent’s authority and may ask you to verify your identity directly.
We will respond within the period required by applicable law.
We ordinarily do not charge for a privacy request. We may charge a reasonable fee or refuse a request where permitted by law, including where it is manifestly unfounded, excessive or repetitive.
16. Account controls
Where available, you may review or update certain information through your account settings.
You may also be able to:
- update profile information;
- change communication preferences;
- manage connected accounts;
- revoke integrations;
- manage cookies;
- export selected information; or
- request account deletion.
Disconnecting an integration prevents future collection through that integration but does not necessarily delete information previously collected.
Account deletion may not remove information that we are required or permitted to retain.
17. Marketing preferences
You may unsubscribe from marketing emails by selecting the unsubscribe link included in the message.
You may also manage available preferences through your account or contact us.
We may retain limited information about an opt-out request to ensure that your preference is respected.
You may continue to receive non-promotional communications relating to:
- your account;
- subscriptions;
- billing;
- security;
- support;
- legal notices;
- material service changes; and
- requested transactions or functionality.
18. Cookies and preference controls
Where available, you can manage non-essential cookies through the cookie-preference tool displayed on the Platform.
Browser and device controls may also allow you to:
- block cookies;
- delete stored cookies;
- limit tracking;
- restrict local storage; or
- control advertising identifiers.
Cookie controls may be device- and browser-specific. You may need to repeat your choices when you use a different browser or device or after deleting cookies.
Strictly necessary technologies may remain active because they are required for security, authentication, preference management or core Platform functionality.
19. Children
The Platform is not directed to children or intended for use by anyone under 18 years of age.
We do not knowingly collect personal data from children through the Platform.
If you believe that a child has provided personal data to us, contact us so that we can investigate and take appropriate action.
20. Third-party services and websites
The Platform may contain links to or integrations with exchanges, wallets, protocols, blockchain networks, payment providers and other third-party services.
This Privacy Policy does not govern the privacy practices of those third parties.
Third parties may independently collect, use and disclose personal data under their own privacy policies and terms.
We encourage you to review the relevant third-party policies before using or connecting a third-party service.
21. Public and shared content
Certain features may allow you to share reports, links, dashboards, configurations or other content.
Information you choose to make public or share with another person may be viewed, copied or redistributed by others.
You should not include personal, confidential or commercially sensitive information in publicly accessible content unless you are authorised and prepared for that information to be disclosed.
22. Changes in purpose
We will generally use personal data only for the purposes for which it was collected or for compatible purposes.
If we intend to use personal data for a materially different purpose, we will provide additional information and, where required, obtain consent before beginning the new processing.
23. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect:
- changes to the Platform;
- new features;
- changes to our processing activities;
- security developments;
- legal or regulatory changes; or
- changes to our service providers.
The updated version will be posted on the Platform with a revised effective date.
Where a change is material, we may provide additional notice through the Platform, by email or through another appropriate communication channel.
We encourage you to review this Privacy Policy periodically.
24. Complaints
You may contact us if you have a question or complaint about how we process personal data.
Depending on your location, you may also have the right to complain to the privacy or data-protection authority responsible for your jurisdiction.
We encourage you to contact us first so that we have an opportunity to address the concern directly.
25. Contact
Questions, complaints, privacy requests and requests for further information may be submitted through the contact or support channels displayed on the Platform.