Welcome to the NEXTHASH privacy notice.

NextHash respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

  • IMPORTANT INFORMATION AND WHO WE ARE
  • THE DATA WE COLLECT ABOUT YOU
  • HOW IS YOUR PERSONAL DATA COLLECTED
  • HOW WE USE YOUR PERSONAL DATA
  • DISCLOSURES OF YOUR PERSONAL DATA
  • INTERNATIONAL TRANSFERS
  • DATA SECURITY
  • DATA RETENTION
  • YOUR LEGAL RIGHTS
  • GLOSSARY

This privacy notice aims to give you information on how NextHash collects and processes your personal data through your use of this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

“the Data Subject” shall refer to all clients, website users, website visitors, and “you”, “your” and “yours” shall refer to all said clients of the Controller, website users and website visitors.

“the Clients” shall refer to all those natural persons who make use of any of the services offered by the Controller on nexthash.com.

“the Account Holder” shall refer to any person who holds an account with the Controller;

“the Website user” shall refer to all those natural persons who make use and/or access data and/or browse and/or visit the Website.

“the Website” shall refer to any website, page, portal, API, application (interpreted in the widest manner possible) on the domain and/or connecting to nexthash.com

“the Website visitor” shall refer to any natural person who looks at and/or visits and/or accesses or, in any manner, views the material on the Website irrespective of the device, platform, browser, application and so on.

NextHash Limited a company incorporated and registered under the Laws of Malta bearing registration number C-85690 and having its registered address at Level 2, Regional Business Centre, University Heights, Msida, MSD 1751, Malta, NexinterExchange OU, a company incorporated and registered under the Laws of Estonia, bearing registration number 14602357 and having its registered address at Roosikrantsi tn 2-527K Kesklinna linnaosa, Tallinn Harju maakond 10119, Estonia and Nexthash d.o.o., a company incorporated and registered under the Laws of Slovenia, bearing registration number 8180814000 and having its registered address at Prešernova cesta 55, 6310 Izola – Isola, Slovenia are the controllers and responsible for your personal data (collectively referred to as “NextHash”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Our full details are:

Full name of legal entity: NEXTHASH LIMITED

Name or title of data privacy manager: Andrea Bartole (email: a.bartole@nexthash.com)

Email address: support@nexthash.com

Postal address: Level 2, Regional Business Centre, University Heights, Msida, MSD 1751, Malta

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), Data Protection Commissioner of Malta for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

The data protection law in Europe has changed on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until November 2018 as we are still working towards getting our systems ready for some of these changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers, website.
  • Financial Data includes bank account, payment card details and information about your income and revenue.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) and process these in accordance with your instructions. We may also collect any information about criminal convictions and offences, if this is required to carry out our services to you in accordance with our letter of engagement and/or your instructions.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (i.e, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • Instruct us to provide you with our services;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
      • analytics providers;
      • advertising networks; and
      • search information providers.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
    • Identity and Contact Data from data brokers or aggregators.
    • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at the following email address: support@nexthash.com

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact at support@nexthash.com you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as a new client

Identity

Contact

Performance of a contract with you

To provide our services to you including:

  • Store personal data and information and disclose these to external third parties, as defined in the Glossary below.
  • Manage payments, fees and charges
  • Collect and recover money owed to us

Identity

Contact

Financial

Transaction

Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

  • Notifying you about changes to our terms or privacy policy
  • Asking you to leave a review

Identity

Contact

Profile

Marketing and Communications

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Identity

Contact

Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, client relationships and experiences

Technical

Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

Identity

Contact

Technical

Usage

Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when registered for a particular financial product or service and, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any company outside NEXTHASH LIMITED for marketing purposes.

You can ask us or third parties to stop sending you marketing messages by contacting us at support@nexinter.com at any time.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://nexthash.com/cookie-policy

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@nexthash.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will transfer the personal data we collect about you outside of the EEA to perform our contract with you.; and

Where there is an adequacy decision by the European Commission thereby deeming such countries to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation; or

Where there is not an adequacy decision by the European Commission such countries will not be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation; and

We have accordingly put in place measures to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

  • Service providers acting as processors based in Malta or anywhere in Europe who provide IT and system administration services, including billing.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, agents and insurers based in Malta or anywhere in Europe or abroad.
  • Professional advisers acting as legal representatives of counterparties.
  • Regulators and other authorities and agencies acting as processors or joint controllers based in Malta or anywhere in Europe or abroad who require reporting of processing activities in certain circumstances.