Privacy and cookies policy
1.1 We are committed to safeguarding the privacy of iCrypts mobile application
1.2 This policy applies where we are acting as a data controller with respect to the personal data of iCrypts mobile application in other words, where we determine the purposes and means of the processing of that personal data.
1.3 In this policy, “we”, “us” and “our” refer to E22 Studio LTD [ For more information about us, see Section 18.]
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 To use the iCrypts Services, you will need to register by providing your name or nickname, email address and a password and accepting the terms of this Agreement. You are fully responsible for all activity that occurs under your iCrypts Account. We may process your name and email (“usage data”). The usage data may include geographical location and mobile version, mobile operating system, length of visit, page views and application navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is Firebase Performance Monitoring. This usage data may be processed to enhance the application usage.
2.3 We may process your name and email address (“account data”). The account data may be processed for ensuring the security of our mobile application and services, maintaining back-ups of our databases and communicating with you.
2.4 We may process your name or nickname and email address (“profile data”). The profile data may be processed for the purposes of enabling and monitoring your use of iCrypts application.
2.5 We may process your name or nickname and email address (“service data”). The service data may include your name or nickname and email address. The source of the service data is E22 Studio LTD. The service data may be processed for the purposes of operating our mobile application, providing our services, ensuring the security of our mobile application and services, maintaining back-ups of our databases and communicating with you.
2.6 We may process your name or nickname and email address information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters] (“notification data”). The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters]. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Automated decision-making
We will not use your personal data for the purposes of automated decision-making.
4. Providing your personal data to others
iCrypts mobile application will not provide your personal data to other third parties inside the European Economic Area (EEA)].
5. International transfers of your personal data
iCrypts mobile application will not provide your personal data to other third parties outside the European Economic Area (EEA)].
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process f–or any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our mobile application.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We will notify you of significant changes to this policy by email.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data (username and email) by visiting your account settings into our mobile application.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 8].
9. Third party websites
iCrypts mobile application does not includes hyperlinks to third party websites or applications.
10. Personal data of children
10.1 Our mobile application is targeted at persons over the age of 18 or legal age in their respective countries.
10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
11. Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
12. About cookies
12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12.4 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
13. Our cookies in our website
We do not use custom cookies on our website.
14. Analytics cookies
14.1 We use Google Analytics to analyse the use of our website.
14.2 Our analytics service provider generates statistical and other information about website use by means of cookies.
14.3 The analytics cookies used by our website have the following names: _ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv.
14.4 The information generated relating to our website is used to create reports about the use of our website.
15. Third party cookies
Our website does not use other third party cookies.
16. Blocking cookies
16.1 Most browsers allow you to refuse to accept cookies; for example:
a – in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
b – in Firefox (version 47) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
c – in Chrome (version 52), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
17. Deleting cookies
17.1 You can delete cookies already stored on your computer; for example:
a – in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
b – in Firefox (version 47), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
c – in Chrome (version 52), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
17.2 Deleting cookies will have a negative impact on the usability of many websites.
18. Acting as a data processor
18.1 In respect of your name or nickname and email, we do not act as a data controller; instead, we act as a data processor.
18.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
18.3 We use Linode Cloud Hosting Service as a Hosting Service provider
18.4 We are registered as a data controller with the UK Information Commissioner’s Office.
18.5 Our data protection registration number is ZA513403.
19. Our details
This mobile application is owned and operated by E22 Studio LTD.
We are registered in England and Wales under registration number 11782831 (under the Nature of business 62012 – Business and domestic software development) and our registered office is at
27 Old Gloucester Street – London, WC1N 3AX.
Our principal place of business is at 27 Old Gloucester Street – London, WC1N 3AX
You can contact any of the officers by email, using firstname.lastname@example.org.
20. Legal Notice and disclaimer
20.1 iCrypts is not providing individually tailored investment advice.
20.2 iCrypts is not registered to provide investment advice.
20.3 iCrypts is not a broker-dealer or financial adviser and is not affiliated with an investment advisory firm.