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How we treat your personal data
Braiins OS is a Linux based operating system for virtual currency mining devices.
Currently, there are two versions of Braiins OS operating system:
i) open-source version called Braiins OS with limited functionality that has been released under the GNU General Public License version 3; and
ii) proprietary version called Braiins OS with full functionality that has been released under a proprietary license and the use of which is subject to license fees.
You may find more information about the Braiins OS on our Website https://braiins.com/ in the BraiinsOS section thereof, where it is also available to download (the “Website”).
Your use of Braiins OS is governed by GNU General Public License version 3 and your use of Braiins OS is governed by the Software License Agreement available on our Website.
Any support we provide to you regarding the Braiins OS or Braiins OS is governed by the Customer Support Agreement available on our Website.
You may have heard about Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the ”Regulation”) more commonly known as GDPR.
Under the Article 13 and 14 of the Regulation, we must provide our customers and other data subjects with information on the collection, handling, protection and processing of their personal data.
Therefore, in this Privacy Policy you may learn more about these topics regarding among others the personal data that we collect when developing Braiins OS, when providing Braiins OS experience to our customers, providing our customers with any related support (technical or other).
We are a commercial company called Braiins Systems s.r.o., with its registered office at Křižíkova 148/34, Karlín, Prague 8, Czech Republic,Id. No. 241 47 931, registered in the commercial register kept by the Municipal Court in Prague under file No. C 183056.
Personal data processed for development
To develop and test BraiinsOS we collect, store and process analytical data related to virtual currency mining that may sometimes be considered as personal data within the meaning of the Regulation. Such data may include, without limitation, for example following information:
- pool settings and username,
- IP address.
Sometimes we use our own materials and sources to obtain necessary data and sometimes we use third party analytical data (obtained from public sources such as internet or via telemetry from customers using our services - for example, when you report an issue and initiate a support procedure, we may use the acquired information for further development of Braiins OS).
We may also collect personal information (such as name, email address etc.) provided by developers that chose to contribute to development of Braiins OS via GitHub.
In all above-mentioned cases some of the information that we collect, store and process for development of Braiins OS may be considered as personal data. In that event, we will, as a data controller collect, store and process such personal data.
When you use your virtual currency mining device with Braiins OS operating system to mine virtual currencies, we may collect and process telemetric data related to your mining activities. Such data may include, without limitation, the following information:
- pool settings and username,
- IP address.
If such telemetric data are considered as personal data, we will, as a data controller, collect,store and process such personal data.
We would like to remind you that under some laws you may be, as an operator of the virtual currency mining device (whether with the Braiins OS operating system or with any other operating system), considered as a personal data controller as well and may be subject to some rules and obligations yourself. If at any time you are not sure, do not hesitate to ask us for more detailed information.
We may provide our customers support services regarding the Braiins OS operating system pursuant to the Customer Support Agreement.
To be able to provide you with any support services we may have to use telemetric data collected when you use your device and any additional data obtained from you during the course of support procedure (such as your contact information, your logs etc.).
If any of such information are considered as personal data, we will, as a data controller, collect,store and process such personal data.
Personal data processed for development
We collect, store and process the above-mentioned analytical data to develop and test our Braiins OS products.
To comply with legal requirements, we must mention that we collect, store and process such personal data pursuant to Article 6 (1)(f) of the Regulation.
That means that it is in our legitimate interest to collect, store and process such personal data, since there is no other effective way to address issues of our software and hardware if we cannot use the data acquired when providing you with our services and since we also make sure that it represents little to no restriction of data subject interests, rights and freedoms.
It is also in our legitimate interest to collect, store and process such personal data to establish,exercise or defend any related legal claims, since otherwise we could not exercise our legal rights and such use of personal data is foreseeable by data subjects and represents little to no restriction of data subject interests,rights and freedoms.
We collect, store and process your personal data only so we can provide you services pursuant to the Software License Agreement and to further develop our products.
We will specifically process your personal data
- to fulfill any of our obligations under the Software License Agreement and any applicable law and to protect our own rights thereunder;
- to secure the quality of our services and to use it for other commercial purposes including informing you of products and services related to Braiins;
- to use it for marketing purposes (research of quality).
To comply with legal requirements, we must mention that we collect, store and process such personal data mainly pursuant to the Article 6 (1) (b) and (f) of the Regulation.
For the legitimate interest explanation please read the section dedicated to the personal data collected via communication, since the similar legitimate interest rules apply.
We collect, store and process your personal data only so we can provide you with services pursuant to the Customer Support Services Agreement and to further develop our products.
- to fulfill any of our obligations under the Customer Support Service Agreement and any applicable law and to protect our own rights thereunder;
- to secure the quality of our services and to use it for other commercial purposes including informing you of products and services related to Braiins;
- to use it for marketing purposes (research of quality).
To comply with legal requirements, we must mention that we collect, store and process such personal data mainly pursuant to the Article 6 (1)(b) and (f) of the Regulation.
For the legitimate interest explanation please read the section dedicated to the personal data collected via contact form, since the similar legitimate interest rules apply.
We collect, process and store your personal data only for the above defined purposes and only to the extent necessary to fulfill these purposes. We never conceal the purpose for which the personal data is collected and further processed.
We process and store your personal data only for the time necessary to meet the purposes of its processing specified above, or for the time consented by you, or for the time that is either necessary to comply with our obligations under the applicable law or set forth by the applicable law or in accordance therewith. We comply with the mandatory rules for data archiving.
Once the purpose of the personal data processing disappears, we will destroy the personal data.
As for the personal data processed for development, we will process and store such personal data only for the period necessary to develop and test Braiins OS (we begin processing immediately after the data are collected) and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law, or set forth by the applicable law or in accordance therewith.
As for the personal data collected when you are using the Braiins OS we will process and store such personal data for as long as you use Braiins OS and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law, or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the provided services.
As for the personal data voluntarily provided by you when we provide you with our support services, we will process and store such personal data until the requested issue is solved and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the requested issue.
We take care of your personal data security and so we choose the partners to whom we entrust your personal data very carefully.
All our partners must be able to provide sufficient security of your personal data to prevent unauthorized or accidental access thereto or other abuse thereof and all our partners must undertake a confidentiality obligation and must not use your personal data for any purpose other than the purpose for which the data were made available to them.
The recipients that may have access to your personal data are following:
- persons who provide us with the technological services or technology operators that we use to provide our services;
- persons who provide our services and Websites with security and integrity and who regularly test such security and integrity;
- providers of accounting, legal and administrative services;
- our staff.
Our aim is and always will beto ensure your personal data are as anonymous as possible and unavailable to all third parties. However, under certain specifically defined conditions we will be under some circumstances required, in accordance with the applicable law, to transfer certain personal data to public authorities.
When collecting, storing and processing personal data we sometimes may use personal data processors such as Google, which under some circumstances transmit your personal data to third countries. In such an event we always make sure such transmission is compliant with the Regulation.
In particular, we specify that the personal data may be transmitted to the United States of America and in such event the transmission is compliant with the Standard Contractual Clauses (SCCs) mechanism.
All your personal data is secured by standard procedures and technologies. We provide data protection against unauthorized or accidental access, alteration, destruction, loss,unauthorized transmission or any other unauthorized processing, as well as against any other abuse of records containing the personal data.
The standard procedures and technologies may include, but are not limited to, the following:
- education and training of relevant staff to ensure they are aware of our privacy obligations when handling personal data;
- administrative and technical rules to restrict access to personal data on a ‘need to know’basis;
- technological security measures, including firewalls, encryption and anti-virus software;
- keeping the most sensitive personal data offline;
- physical security measures, such as staff security passes to access our premises.
We are not able to guarantee the security of your personal data without your help and responsible behavior.Therefore, we ask you to help us ensure the security of your data by keeping in secret and secure your user account login information by following a common security standards.
In relation to the personal data you shall have in particular the following rights:
- aright to withdraw your consent at any time;
- aright to correct or make additions to the personal data;
- aright to request restrictions to processing of your personal data ;
- aright to object or complain against processing of your personal data under certain circumstances;
- aright to request transfer of your personal data ;
- aright to access your personal data;
- aright to be informed of the personal data security breach under certain circumstances;
- aright to request deletion of your personal data (a right to be „forgotten“)under certain circumstances; and
- other rights set forth in Act No. 110/2019 Coll., on personal data processing(Personal Data Protection Act) and the Regulation.
You have a right to object,on grounds relating to your particular situation, at any time to processing your personal data which is based on Article 6(1)(f) of Regulation (it means that we have legitimate interest to process such personal data). You have also a right to object to processing your personal data for direct marketing purposes.
Additionally, you have aright to contact the Office for Personal Data Protection with a request for remedial measures in case of any violation of the obligations set forth in the Regulation at the following address: Office for Personal Data Protection, Pplk.Sochorova 27, 170 00 Prague 7, Czech Republic, phone number +420 234 665 111(central telephone exchange).
If you have any questions regarding this Privacy Policy, please do not hesitate to contact us using the contact details below:
Contract address: Křižíkova148/34, Karlín, Prague 8, Czech Republic
Contact point (support): https://slushpool.kayako.com/en-us/conversation/new/11
Email address: info@braiins.com
This Privacy Policy comesinto effect on the 1st January 2020.
We reserve the right to amendand update this Privacy Policy at any time.
In Prague on 1st January 2020
Braiins Systems s.r.o.
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