Legal
Last updated: Nov 8, 2023
By using Safegate you agree to these terms & disclosures.
If you have any questions about these terms and disclosures or do not agree with it, please contact us on support@safegate.app. Safegate may amend these terms and disclosures from time to time, so you should check this page from time to time to ensure that you are aware of any changes that have been made.
Safegate Privacy Policy
This Privacy Policy (“Policy”) describes how BRS Tech Services Ltd, BVI, its parent or holding company(ies) and its subsidiaries and affiliates (“Brine”, “we”, “us” and “our”) may collect, use and disclose information, and your choices regarding this information.
Please read this Policy carefully and contact us with questions at privacy@brine.fi.
Applicability of This Policy
This Policy applies to the Sites and the Services (in each case, as defined in the Terms of Use). If you do not agree with the terms of this Policy, do not access or use the Services, the Sites, or any other aspect of our business.
What We Collect
When you interact with our Services, we may collect:
- Contact Information, such as your name, email address, physical location address and country information.
- Financial Information, such as your Ethereum network address, cryptocurrency wallet information, transaction history, trading data and associated fees paid.
- Transaction Information, such as information about the transactions you make on our Services, such as the type of transaction, transaction amount, and timestamp.
- Correspondence, such as your feedback, questionnaire and other survey responses, and information you provide to our support teams, including via our help chat or social media messaging channels.
- Online Identifiers, such as username, geo location or tracking details, browser fingerprint, operating system, browser name and version, and IP addresses.
- Information We Get from Others. We may get information about you from other sources as required or permitted by applicable law, including public databases. We may combine the information collected from these sources with the information we get from this Site in order to comply with our legal obligations and limit the use of our Services in connection with fraudulent or other illicit activities.
- Information from cookies and other tracking technologies. We, and third parties we authorize, may use cookies, web beacons, and similar technologies to record your preferences, track the use of our Sites, including our mobile applications, and collect information about the use of the Services, as well as about our interactions with you. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, device information, date or time stamp, and clickstream data, and information about your interactions with the communications we send to you. We may combine this automatically collected log information with other information we collect about you. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of our Services may not function properly.
How We Use Information
We use your information in accordance with your instructions, including any applicable terms in the Terms of Use, and as required by applicable law. We may also use the information we collect for:
3.1 Providing Services and Features. We may use the information we collect to provide, personalize, maintain, and improve our products and Services, including as we described in the Terms of Use. This includes using information to:
- operate, maintain, customize, measure, and improve our Services, and manage our business;
- create and update user accounts;
- send information, including confirmations, notices, updates, security alerts, and support and administrative messages; and
- to create de-identified or aggregated data.
3.2 Safety and Security. We may use your information to help maintain the safety, security, and integrity of you and our Services, including to:
- protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
- monitor and verify identity or service access, combat spam, malware or security risks;
- perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems;
- enforce our agreements with third parties, and address violations of our Terms of Use or agreements for other products or services; and
- comply with applicable security laws and regulations.
3.3 Customer Support. We may use information we collect to provide customer support, including to:
- direct questions to the appropriate customer support person;
- investigate and address user concerns; and
- monitor and improve our customer support responses and processes.
3.4 Research and Development. We may use the information we collect for testing, research, analysis, and product development to improve your experience. This helps us to improve and enhance the safety and security of our Services, improve our ability to prevent the use of our Services for illegal or improper purposes and develop new features and products relating to our Services.
3.5 Legal and Regulatory Compliance. We may verify your identity by comparing the personal information you provide against third-party databases and public records. We may use the information we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
3.6 Direct Marketing. We may use the information we collect to market our Services to you. This may include sending you communications about our Services, features, promotions, surveys, news, updates, and events, and managing your participation in these promotions and events. If you do not want us to send you marketing communications, please opt out by selecting “unsubscribe” to any marketing email sent by us or by contacting us at privacy@brine.fi.
Content
Content posted on the Service is published as of its stated date or, if no date is stated, the date of first posting. Neither Safegate nor the Third-Party Providers have undertaken any duty to update any such information.
Safegate does not prepare, edit, or endorse Third Party Content. Safegate does not guarantee the accuracy, timeliness, completeness or usefulness of Third Party Content, and is not responsible or liable for any content, advertising, products, or other materials on or available from third party sites.
You will not hold Safegate and/or any Third-Party Provider liable in any way for (a) any inaccuracy of, error or delay in, or omission of the Content; or (b) any loss or damage arising from or occasioned by i) any error or delay in the transmission of such Content; ii) interruption in any such Content due either to any negligent act or omission by any party to any “force majeure” (e.g., flood, extraordinary weather conditions, earthquake or other act of God, fire, war, insurrection, riot, labor dispute, accident, action of government, communications or power failure, equipment or software malfunction), or iii) to any other cause beyond the reasonable control of Safegate and/or Third-Party Provider, or iv) non-performance.
Content
Content posted on the Service is published as of its stated date or, if no date is stated, the date of first posting. Neither Safegate nor the Third-Party Providers have undertaken any duty to update any such information.
Safegate does not prepare, edit, or endorse Third Party Content. Safegate does not guarantee the accuracy, timeliness, completeness or usefulness of Third Party Content, and is not responsible or liable for any content, advertising, products, or other materials on or available from third party sites.
You will not hold Safegate and/or any Third-Party Provider liable in any way for (a) any inaccuracy of, error or delay in, or omission of the Content; or (b) any loss or damage arising from or occasioned by i) any error or delay in the transmission of such Content; ii) interruption in any such Content due either to any negligent act or omission by any party to any “force majeure” (e.g., flood, extraordinary weather conditions, earthquake or other act of God, fire, war, insurrection, riot, labor dispute, accident, action of government, communications or power failure, equipment or software malfunction), or iii) to any other cause beyond the reasonable control of Safegate and/or Third-Party Provider, or iv) non-performance.
Any price quotes may be delayed 20 minutes or longer, according to the rules and regulations applicable to exchanges and Third Party Providers. Neither Safegate nor the Third-Party Providers make any representations, warranties or other guarantees as to the accuracy or timeliness of any price quotes. Neither Safegate nor the Third-Party Providers make any representations, warranties or other guarantees as to the present or future value or suitability of any sale, trade or other transaction involving any particular security or any other investment.
Content is provided exclusively for personal and non-commercial access and use. No part of the Service or Content may be copied, reproduced, republished, uploaded, posted, publicly displayed, encoded, translated, transmitted or distributed in any way (including “mirroring”) to any other computer, server, web site or other medium for publication or distribution or for any commercial enterprise, without Safegate’s express prior written consent.
You acknowledge that Safegate is the sole owner of Safegate Marks and that other Marks are the property of their respective owners. You agree that you will not use any Marks for any purpose without the prior express written consent of the respective owners.
Termination; Modification
You agree that, without notice, Safegate may terminate these Terms and Conditions, or suspend your access to the Service or the Content, with or without cause at any time and effective immediately. These Terms and Conditions will terminate immediately without notice from Safegate if you, in Safegate’s sole discretion, fail to comply with any provision of these Terms and Conditions. Safegate shall not be liable to you or any third party for the termination or suspension of the Service or the Content, or any claims related to such termination or suspension. Safegate may also terminate or suspend your access to the Service or the Content if Safegate finds that your usage violates these Terms and Conditions, or if your usage puts an undue strain on Safegate’s information technology infrastructure.
Safegate and/or the Third-Party Providers may discontinue or modify the Content, or any portion thereof, at any time. You release and agree to indemnify and hold harmless Safegate, and the Third-Party Providers, for any loss or damages arising from or relating to such discontinuation or modification.
Communications
By using the Service or the Content, you consent to any form of recording and retention of any communication, information and data exchanged between you and Safegate or its representatives or agents.
All communications made at or through the Forums are public. Neither Safegate nor the Third-Party Providers screen, review, approve or endorse any Third Party Content available on or through the Forums.
Reliance on any Third Party Content available on or through the Forums is at your own risk. When discussing a particular company, stock or security in the Forums, you agree to reveal any ownership interest in such company, stock or security. Without limitation, you agree not to do any of the following:
- upload, post, transmit or otherwise make available any Content that is unlawful, harmful, threatening, abusive, harassing, tortuous, defamatory, vulgar, obscene, libelous, invasive of another ’s privacy (including, but not limited to, any address, email, phone number, or any other contact information without the written consent of the owner of such information), hateful, or racially, ethnically or otherwise objectionable;
- harm minors in any way;
- impersonate any person or entity, including, but not limited to, (i) an Safegate or Third-Party Provider manager, employee, agent, or representative or (ii) forum leader, guide or host;
- falsely state or otherwise misrepresent your affiliation with any person or entity;
- forge headers or otherwise manipulate identifiers in order to disguise the origin of any material;
- upload, post or otherwise transmit any material that you do not have a right to transmit under any law or under contractual or fiduciary relationships (such as inside information, proprietary and confidential information learned or disclosed as part of employment relationships or under nondisclosure agreements);
- upload, post or otherwise transmit any material that infringes any patent, trademark, trade secret, copyright, rights of privacy or publicity, or other proprietary rights of any party;
- upload, post, or transmit unsolicited commercial email or “SPAM,” including, but not limited to, unethical marketing, advertising, or any other practice that is in any way connected with SPAM, such as: (1) sending mass email to recipients who haven ’t requested email from you or with a fake return address; (2) promoting a site with inappropriate links, titles, or descriptions; or (3) promoting any site by posting multiple submissions in forums that are identical;
- upload, post or otherwise transmit any material that contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment;
- interfere with or disrupt the Service or servers or networks connected to the Service, or disobey any requirements, procedures, policies or regulations of networks connected to the Service;
- intentionally or unintentionally violate any applicable local, state, national or international law, including, but not limited to, regulations promulgated by the U.S. Securities and Exchange Commission, any rules of any national or other securities exchange, and any regulations having the force of law;
- “stalk” or otherwise harass another;
- collect or store personal data about other users of the Service;
- promote or provide instructional information about illegal activities, promote physical harm or injury against any group or individual, or promote any act of cruelty;
- promote, offer for sale or sell any security or item, good or service that i) violates any applicable federal, state, or local law or regulation, ii) you do not have full power and authority under all relevant laws and regulations to offer and sell, including all necessary licenses and authorizations, or iii) Safegate or the Third Party Providers determine, in their sole discretion, is inappropriate for sale;
- use the Forums as a forwarding service to another website; or
- access or otherwise use the Forums in any unlawful manner, for any unlawful purpose or in violation of these Terms and Conditions.
External Links
Safegate and/or the Third-Party Providers may provide links to other websites or resources. Because neither Safegate or the Third-Party Providers have any control over such sites and resources, you acknowledge and agree that neither Safegate nor the Third Party Providers are responsible for the availability of such external sites or resources. Safegate and the Third Party Providers do not endorse and are not liable for any content, advertising, products, or other materials on or available through such sites or resources. You further acknowledge and agree that neither Safegate nor the Third Party Providers shall be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such site or resource.
Applicable Policies
In addition to these Terms and Conditions, your access to and use of the Content and the Service is subject to Safegate’s then-current policies relating to the Content and the Service, including, without limitation, the Safegate Privacy Policy available on the Service. You agree to be bound by these policies and all other Safegate policies applicable to the access and use of the Content and the Service.
By using the Service, you are consenting to have your personal data transferred to and processed by Safegate and its affiliates. As part of providing you the Service, Safegate may need to provide you with certain communications, such as service announcements and administrative messages. These communications are considered part of the Service, which you may not be able to opt-out from receiving.
Indemnification
You will indemnify and hold harmless Safegate and the Third Party Providers, and the officers, directors, agents, partners, employees, licensors, distributors, and representatives of Safegate and the Third Party Providers, from and against any and all claims, demands, actions, causes of action, suits, proceedings, losses, damages, costs, and expenses, including reasonable attorneys ’fees, arising from or relating to your access and/or use of, or interaction with the Content (including, without limitation, Third Party Content), or any act, error, or omission of your use of your account or any user of your account, in connection therewith, including, but not limited to, matters relating to incorrect, incomplete, or misleading information; libel; invasion of privacy; infringement of a copyright, trade name, trademark, service mark, or other intellectual property; any defective product or any injury or damage to person or property caused by any products sold or otherwise distributed through or in connection with the Service; or violation of any applicable law.
Revisions
Safegate may at any time revise these Terms and Conditions by updating this document and making it available to you through the Services. You agree to be bound by subsequent revisions and agree to review these Terms and Conditions periodically for changes. The most updated version of this document will be available for your review under the “Safegate Terms and Conditions” link that appears on the Safegate website and mobile application.
Data Retention
To view or update your information, contact us at privacy@brine.fi. We store your information throughout the life of your use of the Services and thereafter.
Security
We maintain administrative, technical and physical safeguards designed to protect the personal information we maintain against unauthorized access or disclosure and require our third-party service providers to have appropriate safeguards. No system can be completely secure. Therefore, although we take steps to secure your information, we cannot guarantee that your information, searches, or other communication will always remain secure. You are responsible for all activity on the Safegate protocol relating to any of your Ethereum or other network addresses or cryptocurrency wallets.
Age Limitation
To the extent prohibited by applicable law, we do not allow use of our Services or Sites by anyone younger than 18 years old. If you learn that anyone younger than 18 years old has unlawfully provided us with personal data, please contact us at privacy@brine.fi and we will take steps to delete such information, close any such accounts, and, to the extent possible, prevent the user from continuing to use our Services.
Online Tracking Opt-Out Guide
Like many companies online, we use services provided by Google and other companies that use tracking technology. These services rely on tracking technologies—such as cookies and web beacons—to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:
- Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
- Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
- Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third-party cookies or trackers.
- Platform opt-outs. The following advertising partner offers opt-out features that let you opt-out of use of your information for interest-based advertising: Google: https://adssettings.google.com.
- Advertising industry opt-out tools. You can also use the opt-out options set forth below to limit use of your information for interest-based advertising by participating companies. Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use. : Digital Advertising Alliance: http://optout.aboutads.info
Notice to European Union Residents ("GDPR Notice")
In accordance with the General Data Protection Regulation (the “GDPR”), we are providing this GDPR Notice to European Union (“EU”) residents to explain how we collect, use and share their personal data (as defined in the GDPR), and the rights and choices we offer EU residents regarding our handling of their personal information.
GDPR
We process personal data for the purposes described in the How We Use Information section of this Policy. As an EU resident, you have various rights in connection with the processing of your personal data as follows:
You have the right to information about your personal data processed by us and to the following information: (a) the processing purposes; (b) the categories of personal data being processed; (c) the recipients or categories of recipients to whom the personal data have been or are being disclosed, in particular recipients in third countries or international organizations; (d) if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration; (e) the existence of a right to rectification or deletion of your personal data, to restricting the processing of your personal data or to objecting to such processing; (f) the existence of a right of appeal to a supervisory authority; (g) if the personal data is not collected from you, all available information about the origin of the data; (h) the existence of automated decision-making and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject; and (i) in the case of the transfer of personal data to a third country or an international organization, on the appropriate safeguards in relation to the transfer.
You have the right to immediately request the rectification of inaccurate personal data concerning you and, taking into account the purposes of the processing, the completion of incomplete personal data, by means of providing a supplementary statement.
You have the right to request the immediate erasure of personal data concerning you and we are obliged to delete this data immediately if one of the following reasons applies: (i) the personal data are no longer necessary for the purposes for which they were collected or otherwise processed; (ii) you revoke your consent on which the processing was based under Article 6(1)(a) or Article 9(2)(a) of the GDPR and there is no other legal basis for the processing; (iii) you object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for processing or you object to the processing pursuant to Article 21(2) of the GDPR; (iv) your personal data has been processed unlawfully; (v) the deletion of your personal data is necessary to fulfill a legal obligation under EU law or the law of the member states to which we are subject; (vi) the personal data have been collected in relation to information society services provided in accordance with Article 8(1) of the GDPR. If we have made personal data public and are obliged to erase personal data in accordance with Article 17(1) of the GDPR, we will take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform controllers who process the personal data you have requested the erasure by such controllers of any links to or copies or replications of, such personal data.
The rights in the foregoing paragraph do not apply to the extent that processing is necessary (A) to exercise the right of freedom of expression and information; (B) to fulfill a legal obligation required for processing under EU law or the law of the member states to which we are subject; or (C) to assert, exercise or defend legal claims.
You have the right to request us to restrict processing if one of the following conditions is met: (1) the accuracy of the personal data is contested by you, for a period of time that enables us to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose to delete the personal data and instead requests the restriction of the use of your personal data; (3) we no longer need your personal data for the purposes of processing, but you do need it to assert, exercise or defend legal claims; or (4) you have objected to the processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate interests of our company override your legitimate interests.
You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit this data to another controller without hindrance, provided that the processing is based on a consent pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR and the processing is carried out by automated means. When exercising your right to data portability, you have the right to have your personal data transferred directly by us to another controller, to the extent that such transfer is technically feasible.
You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) of the GDPR, including profiling based on these provisions. We will no longer process your personal data unless we can demonstrate compelling legitimate reasons for the processing that override your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims.
You have the right to revoke your consent to the processing of your personal data at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until revocation.
If you wish to assert your rights to information, correction, deletion or restriction of processing, object to data processing or revoke your consent to data processing, please send an email to privacy@brine.fi. If you consider that the processing of personal data concerning you infringes the GDPR, then you can lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement.
Market Volatility Disclosure
This Statement seeks to provide you with an overview of some of the major risks associated with your Investments and Transactions from a market volatility perspective. It does not purport to be a comprehensive description of all the significant risks or other aspects of your Investments and Transactions.
Delays
In a fast-moving market, attempts at cancelling an existing order and replacing it with a new one may result in an execution of duplicate orders. In such situations, customers are wholly responsible for both executions and any resulting losses. High volumes of trading at the market opening or intra-day may cause delays in execution and executions at prices significantly away from the market price quoted or displayed at the time the order was entered. Market Makers may execute orders manually or reduce their size guarantees during periods of volatility, resulting in possible delays in order execution and losses. Using limit orders is highly recommended in order to avoid executions at prices significantly different from the prices quoted at the time of order entry.
Quotes
In times of high market volatility, significant price discrepancies may exist between the quote (real time or delayed) received by the customer and the price at which the trade is executed. In addition, the number of shares available at a certain price (known as the size of a quote) may change rapidly, affecting the likelihood of a quoted price being available to the customer. Enhanced risk exists in this market environment for investors who employ short-term strategies such as day trading.
Types of Orders
We are required to execute a market order fully and promptly without regard to price. While a customer may receive a prompt execution of a market order, the execution may be at a price significantly different from the current quoted price of that security. Limit orders will be executed only at a specified price or better. While the customer receives price protection, there is the possibility that the order will not be executed.
Access
Customers may suffer market losses during periods of volatility in the price and volume of a particular stock when systems problems result in inability to place buy or sell orders. Customers trading on-line may have difficulty accessing their accounts due to high Internet traffic or because of systems capacity limitations. When on-line trading has been disabled or is not available because of systems limitations, customers may have difficulty reaching account representatives on the telephone during periods of high volume. While every effort is made to ensure the availability of electronic systems and brokers, no guarantee of access can be made during periods of exceptionally heavy activity. In addition, system response and account access times may vary, or service may be interrupted due to other conditions, including system performance, Internet traffic levels and other factors.