This Privacy Policy ("Privacy Policy”) explains how your information is collected and used when you visit the
Brute Brothers website at https://brutebrothers.com (the "Website”)
and use the Brute Brothers service (collectively, the "Service”), which are operated by Brute Brothers
Ltd. ("Company” or "we”, "us”, "our”). It also describes the rights and options
available to you with respect to your personal information.
We are committed to protecting and respecting your privacy. Please read this Privacy Policy carefully.
Contact Information
When you fill in the “Contact Us” form, we collect your name, your email address, and
additional details you provide regarding your request, such as your wallet type and the reason for contacting
us (e.g. loss of password).
Wallet Information
We collect the encrypted cryptocurrency wallet file, passwords you usually use,
public crypto addresses that you used, crypto seed phrases, and any other information related to the
encrypted wallet. We also collect a new cryptocurrency wallet address.
Legal Obligation
You do not have a legal obligation to provide the above information. However, you will not be able to contact
us through the Website, and we will not be able to provide you with the Service without providing the above
information.
Analytics Information
When you interact with the Website, we record and collect certain information about
your interaction with the Website, including the IP address from which you access the Website, your estimated
location based on your IP, time and date of access, type of browser used, language used, links clicked and
actions taken while using the Website.
We process your data for the following purpose
To Communicate with you and initiate the provision of the Service
We process your Contact Information to enable communication with you and initiate the provision of the
Service.
To provide you the Service
We process your Wallet Information to operate and provide you with the Service.
For security and monitoring purposes
We process your Analytics Information for security and monitoring purposes.
To develop and improve the Website.
We process your Analytics Information to understand how users interact with the Website so that we can
personalize, develop and improve the Website.
We will share your information with our service providers helping us to operate the Service
We will share your personal information with our service providers who assist us with the internal operations
of the Service. These companies are authorized to use your personal information only as necessary to provide
these services to us and not for their own purposes. The service providers we use are: Monday.
If you violate the law, we will share your information with competent authorities.
If you have abused your rights to use the Service, or if you violated any applicable law, we will share your
information with competent authorities and with third parties (such as legal counsels and advisors), for the
purpose of handling of the violation or breach.
We will share your information if we are legally required to do so.
We will share your information if we are required to do so by a judicial, governmental, or regulatory
authority.
We will share your Information with third parties in any event of change in our structure.
If the operation of our Service is organized within a different framework, or through another legal structure
or entity (such as due to a merger or acquisition), we will share information only as required to enable the
structural change in the operation of the business.
We will retain your Information for as long as we need it for providing you the Service, and
thereafter as
needed for record-keeping matters
We will retain your Information for the duration needed to provide you with the Service. Thereafter, we will
still retain it as necessary to comply with our legal obligations, resolve disputes, establish and defend
legal claims and enforce our agreements.
We implement measures to secure your Information.
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of
information. However, these measures do not provide absolute information security. Therefore, although efforts
are made to secure personal information, it is not guaranteed, and you cannot expect that the Service will be
immune from information security risks.
We will internationally transfer your information in accordance with applicable data protection
laws.
If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data
transfer rules applicable to these situations.
We are the data controller of the personal data we collected through the Website and Service
Brute Brothers LTD is the data controller of the personal data we collect and process through the Website and
Service.
Cross-border transfers
Information we collect from you will generally be processed within the EU and in Israel which is recognized by
the European Commission as having adequate protection for personal data.
If we transfer your information from the EU to other jurisdictions outside the EU, we will do so using
adequate safeguards determined by the EU Commission.
Legal basis under EU law for processing your personal data
The legal basis under EU law for processing your Contact Information and Wallet information is the performance
of our Terms of Use contract with you and our legitimate interest in the operation of the Service.
The legal basis under EU law for processing your Analytics Information is our legitimate interest in
monitoring, securing, developing and improving our Website.
The legal basis under EU law for processing your data for the purpose of handling instances of abusive use of
the Service is our legitimate interest in defending and enforcing against violations and breaches that are
harmful to our business.
The legal basis under EU law for processing your data where we are legally required to share it, is our
legitimate interest in complying with mandatory legal requirements imposed on us.
The legal basis under EU law for us processing your data in the event of a change in our corporate structure
is our legitimate interest in our business continuity.
You have certain rights to access, update or delete your information, obtain a copy of your
information, withdraw your consent, and object or restrict certain data processing activities
If you are in the EU, you have the following rights under the GDPR:
Right to Access your personal data that we process and receive a copy of it.
Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data
completed.
Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured,
commonly used and machine-readable format. You have the right to transmit this data to another service
provider. Where technically feasible, you have the right that your personal data be transmitted directly from
us to the service provider you designate.
Right to Object, based on your particular situation, to using your personal data on the basis of our
legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds,
or for the establishment, exercise of defense of legal claims.
Right to Restrict the processing your personal data (except for storing it) if you contest the accuracy of
your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is
unlawful and you oppose the erasure of the personal data and request instead to restrict its use; if we no
longer need the personal data for the purposes outlined in this Policy, but you require them to establish,
exercise or defense relating to legal claims, or if you object to processing, pending the verification whether
our legitimate grounds for processing override yours.
Right to be Forgotten. Under certain circumstances, such as when you object to us processing your data and we
have no compelling legitimate grounds to override your objection, you have the right to ask us to erase your
personal data. However, we may still process your personal data if it is necessary to comply with a legal
obligation that we are subject to under laws in EU Member States or for the establishment, exercise or defense
of legal claims.
If you wish to exercise any of these rights, contact us at [email protected].
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with
information. Where we are not able to provide you with information that you have asked for, we will explain
the reason for this.
You have a right to submit a complaint to the relevant supervisory data protection authority
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority.
If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory
authority, in particular in the Member State of your residence, place of work or place of alleged infringement
of the GDPR. For a list of supervisory authorities in the EU, click here.
If we change this Privacy Policy, we will make efforts to proactively notify you of such
changes
From time to time, we may change this Privacy Policy. If we do so, we will make efforts to proactively notify
you of such changes. In any event, the latest version of the Privacy Policy will always be accessible on the
Website.
Last Update: March 21, 2021.
