Privacy Policy
Last Updated: Oct 25, 2023
This Privacy Policy describes how your personal information is collected, used, and disclosed with or by bitFlyer USA, Inc. (“bitFlyer,” “we,” or “us”) when you access our Services, which include services offered on our website https://bitflyer.com/en-us/ or when you use the bitFlyer mobile apps or other products and services owned and operated by bitFlyer USA, Inc. (collectively, the “Services”) or when you otherwise interact with bitFlyer as a prospective customer or customer. By accessing and using bitFlyer services you hereby attest that you are at least 18 years of age and consent to this Privacy Policy and the terms contained herein.
bitFlyer values your privacy and encourages all our customers to be familiar with this Privacy Policy as well as our Terms of Use. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, we may provide you with additional notice (such as by adding a statement to the homepage of our website, or by sending you an email notification).
IF YOU DO NOT AGREE TO BE BOUND BY THIS PRIVACY POLICY, YOU SHOULD NOT VISIT, ACCESS OR USE BITFLYER. For additional information about the choices we provide you in connection with our privacy practices, please see the “Your Choices” section below.
Information We Collect
Personal Information You Provide to Us
We collect personal information you provide to us when you register for an account, execute a transaction, link an external account to the Services, sign up to receive email updates, fill out a form or survey, participate in a marketing campaign, or when you otherwise communicate with us. The types of personal information we may collect include your name, phone number, email address, bank account information, username, password, social security number, birthdate, driver’s license or passport number, and any other information as may be required for you to provide. We may also request supplemental identification information, including but not limited to utility bills, bank statements, employment information, proof of income, or photographs and/or videos. Other forms of information about you also include: Electronic Identification Information (“EIDV”), corporate information, wallet information, financial information, or additional information that may be required when you use the services.
Personal Information We Collect Automatically from our Services
When you use the Services, the information we automatically collect about you includes but is not limited to:
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Transaction Information. We collect information in connection with each transaction you engage in via the Services, including transaction time, amount of transaction, and other transaction details.
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Log Information. We collect standard server logs in connection with your use of our Services, including the type of browser you use, access times, pages viewed, IP address and the web page you visited before navigating to our Services.
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Device Information. We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
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Location Information. We may collect mobile device location information in connection with your use of our mobile app.
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Information Collected by Tracking Technologies. We may use various technologies to collect information in connection with your use of our Services, including the following:
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Cookies, which are small files that are sent to your computer or mobile device when you visit a website. Cookies allow our websites to recognize your browser and track your usage each time you visit,
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Local storage, which stores data locally in your browser, including user preferences; and
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Pixel tags, which are small blocks of code often used in connection with cookies. Pixel tags (or web beacons) may be placed on our websites and emails and allow us to track website usage and determine when emails have been opened and acted upon.
Personal Information from Other Sources
We collect personal information from third parties and associate that with the personal information we collect from you. For example, in connection with your creation of an account, we may collect personal information about you from identity verification services to verify your identity; including but not limited to your prior addresses and aliases. We may receive information about you from public databases, such as the Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals And Blocked Persons List (“SDN”) or other relevant law or regulatory enforcement agency, including your name, address, email address, phone number, gender, national ID number and nationality/country of residence, date of birth, job role, public employment profile, listing on any sanctions lists maintained by public authorities, and other data as necessary. We may use public blockchain data, including timestamps of transactions or events, transaction IDs, digital signatures, transaction amounts, and wallet addresses.
Use of Personal Information
We may disclose personal information with third-party service providers (including those that may be located outside of the United States), who assist us in performing our services, maintaining our systems, and detecting fraud and security threats throughout the normal course of our business. All third-party service providers are subject to strict confidentiality and non-disclosure obligations.
We use the information we collect about you to:
- Provide, maintain, deliver, and improve our Services,
- Develop new products and services,
- Send you technical notices and support and administrative messages,
- Communicate with you about products, services, promotions, events and other news and information we think will be of interest to you,
- Personalize our Services, including by providing content, advertisements or features we think will be of interest to you,
- Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards,
- Monitor and analyze trends, usage and activities in connection with our Services,
- Detect and prevent fraudulent transactions and other illegal activities and protect the rights and property of bitFlyer and others; and
- Carry out any other purpose for which the information was collected.
We are required by law to collect and store various pieces of personal information to properly identify or confirm your identity to comply with specific anti-money laundering (“AML”) or sanctions laws/regulations (e.g. funds transfer rules). Our verification processes also involve electronic identification through the comparison of your ‘selfie’ against your provided verification documents and/or information. All such information is securely maintained by bitFlyer and its service providers and is only disclosed where permitted or required by law.
We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with law, legal obligations, regulations, law enforcement, governmental, and other legal requests, court orders, or for disclosure to tax authorities.
Disclosure of Information
We may disclose personal information we collect with third-party service providers and our affiliates. We may also disclose any personal information we collect about current and former customers with non-affiliated third parties, as follows:
(1) With service providers that perform services on our behalf, including identity verification services and email marketing services,
- We use Plaid to connect your bitFlyer account with your bank account, verify your bank account, and confirm your bank account balance prior to approving a transaction. Information disclosed to Plaid is treated by Plaid in accordance with the Plaid End User Privacy Policy. By linking your bank account through Plaid, you consent to Plaid’s Privacy Policy.
- We use Au10tix to perform various identity verification services on our behalf, including but not limited to the collection, usage, and storage of biometric identifiers and/or information. Information collected and disclosed to Au10tix is treated in accordance with Au10tix’s Biometric Data Policy, including data retention. By completing account sign up with bitFlyer, you consent to the use of such data collected from you.
(2) With other companies, in the normal course of business, to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may disclose information about you as follows:
- To comply with an applicable law or regulation, or in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process,
- To protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability,
- To protect the rights, property and safety of bitFlyer or others,
- In connection with a proposed or actual sale, merger, transfer or exchange of all or a portion of bitFlyer’s assets to another company; and
- With your consent or at your direction, including if we notify you that the information you provide will be disclosed in a particular manner and you provide such information.
TRUST is a global, secure, and industry-driven solution designed to comply with a requirement known as the Travel Rule while protecting your security and privacy. bitFlyer and other custodial cryptocurrency exchanges and financial institutions disclose certain basic information about their customers when sending funds over a certain amount to another financial institution. To learn more, see Travel Rule FinCEN Advisory.
Data Retention
We retain your information as required to provide our Services, comply with legal and regulatory obligations, or protect our or others’ interests. While retention requirements vary by country and/or US state, we maintain internal retention policies based on how information needs to be used. This includes considerations such as when the information was collected or created, whether it is necessary to continue offering you our Services, whether we are required to hold the information to comply with our legal obligations, including AML/KYC compliance or other financial regulatory obligations, or information preservation requirements. We also keep certain information where necessary to ensure the safety of bitFlyer, its affiliates, partners, and/or employees.
We may retain biometric information for the period required for financial regulatory compliance or otherwise as required by applicable law. Our third-party identity verification service providers retain this information for as long as set out in their applicable notices/policies.
In line with these considerations, we may delete information that is no longer needed for the above purposes when you close your account, or when you request deletion of your information. If you have any questions, please reach out to Customer Support at info.us@bitflyer.com.
Transfer of Information to the U.S. and Other Countries
bitFlyer is based in the United States and the information we collect is governed by U.S. law. By accessing or using our Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law. Where this may be the case, we will take appropriate measures to protect personal information about you in accordance with this Privacy Policy.
Social Sharing Features
The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on the Services with other external sources, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Advertising and Analytics Services Provided by Others
We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in mobile apps. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and apps, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by bitFlyer and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other online services and better understand your online activity. You may be able to opt out of having third parties use your web browsing information for behavioral advertising purposes, by visiting www.aboutads.info/choices. You may also be able to opt out of having third parties use information collected through apps for behavioral advertising purposes by visiting your mobile device operating system settings.
Security
bitFlyer takes reasonable measures designed to protect information we collect about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction, including by implementing security practices and procedures to protect the confidentiality and security of the information we collect about you in accordance with our privacy policy. We use reasonable measures designed to limit access to the information we collect about you to employees that have a reasonable business reason to know such information.
Your Choices
Account Information.
You may access and update your account profile information by logging into your account via our Services. If you wish to delete account information, you can delete your account by emailing Customer Support at info.us@bitflyer.com but note that we may retain certain information as required by law or for our legitimate business purposes.
Promotional Communications.
You may opt out of receiving promotional communications from bitFlyer by following the instructions in those messages. Please note that if you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.
Location Information.
If you initially consent to the collection of location information by bitFlyer within our mobile app, you may be able to subsequently stop this collection through your device operating system settings or you may also disable location information by removing our mobile app from your device.
Cookies and Local Storage.
Most web browsers are set to accept cookies and local storage by default. If you prefer, you can usually choose to set your browser to remove browser cookies or clear local storage. Please note that if you choose to remove or reject these technologies this could affect the availability and functionality of our Services, including, if you disable cookies, your ability to receive electronic communications.
Contact Us
If you have questions about this Privacy Policy, please contact Customer Support at info.us@bitflyer.com.