Data Privacy Notice
We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (EU-GDPR) as well as current national data privacy regulations. Please read this data privacy information carefully before submitting a report.
1. Purpose of the whistleblowing system and legal basis
The whistleblowing system (BKMS® System) serves the purpose of securely and confidentially receiving, processing and managing reports regarding violations of the compliance rules of Bitpanda. The processing of personal data in the BKMS® System is based on the legitimate interests of our company to detect and prevent misconduct and thus avoid damage to Bitpanda, its employees and customers. Article 6 (1) (f) EU-GDPR serves as legal basis for this data processing.
2. About Bitpanda Group
Bitpanda GmbH and its direct and indirect subsidiaries (hereinafter referred to as "Bitpanda" or "Bitpanda Group" or "we") offer via its websites www.bitpanda.com, exchange.bitpanda.com and its mobile application (“Mobile App”) (together hereinafter referred to as "website" or “platform”) services and products related to buying and selling cryptocurrencies and other digital assets as well as payment and IT services.
Bitpanda GmbH with its business address at Stella-Klein-Löw-Weg 17, 1020 Vienna, Austria, registered in the commercial register of the Commercial Court of Vienna under FN 423018k is the parent company and is the content provider of the Platform as well as responsible for the offer of cryptocurrencies on it.
Bitpanda Group consists of the following companies which are all subsidiaries of Bitpanda GmbH:
- Bitpanda Metals GmbH: has its business address at Stella-Klein-Löw-Weg 17, 1020 Vienna, Austria, is registered in the commercial register of the Commercial Court of Vienna under FN 511923 d, and offers trading with precious metals via the platform www.bitpanda.com.
- Bitpanda Payments GmbH: has its business address at Stella-Klein-Löw-Weg 17, 1020 Vienna, Austria, is registered in the commercial register of the Commercial Court of Vienna under FN 501412x, and offers different payment services via the platform www.bitpanda.com.
- Bitpanda UK Limited: has its business address at 68 Hanbury Street, E1 5JL, London, United Kingdom, is registered in the Companies House under company number 11106704, and acts as a service provider for the Bitpanda Group.
- Pantos GmbH: has its business address at Stella-Klein-Löw-Weg 17, 1020 Vienna, Austria, is registered in the commercial register of the Commercial Court of Vienna under FN 481562 f, and develops new blockchain applications and offers its own cryptocurrency via the platform www.bitpanda.com, see also http://www.pantos.io/.
- Bitpanda Customer Care GmbH: has its business address at Stella-Klein-Löw-Weg 17, 1020 Vienna, Austria, is registered in the commercial register of the Commercial Court of Vienna under FN 523486 h and acts as a service provider for the Bitpanda Group.
- Bitpanda Financial Services GmbH: has its business address at Stella-Klein-Löw-Weg 17, 1020 Vienna, Austria, is registered in the commercial register of the Commercial Court of Vienna under FN 551181 k and acts as a service provider for the Bitpanda Group and provides the reception and transmission of orders in accordance with the Austrian Securities Supervision Act 2018 (Wertpapieraufsichtsgesetz 2018 or “WAG”).
- Bitpanda Asset Management GmbH: has its business address at Friedrich-Ebert-Anlage 36, 60325 Frankfurt am Main, Germany and is registered in the commercial register of the Commercial Court of Frankfurt am Main under HRB 121696.
- Bitpanda Teknoloji A.Ş.: has its business address at Esentepe Mahallesi Kir Gülü Sk. Metrocity is Merkezi D, Block Apt. No 4/4, Şişli, Istanbul, Turkey, is registered in the Trade Register of Istanbul under 243948-5 and is a service provider for the Bitpanda Group.
- Bitpanda Technology sp. z o.o.: has its business address ul. Wadowicka 7, 30-347 Kraków, Poland, registered in the commercial register of the Commercial Court of Kraków 888374, and is a service provider for the Bitpanda Group.
- Bitpanda Issuance GmbH: has its business address at Friedrich-Ebert-Anlage 36, 60325 Frankfurt am Main, Germany registered in the commercial register of the District Court of Charlottenburg under HRB 226876B, and is a service provider for the Bitpanda Group.
- Bitpanda Technology UK Limited: has its business address 21 Holborn Viaduct, EC1A2DY, London, United Kingdom, registered in the commercial register under 13515477, and is a service provider for the Bitpanda Group.
3. Responsible authority
The party responsible for data privacy in the whistleblowing system is
- Bitpanda GmbH and
- its subsidiaries
as parties with mutually autonomous responsibility (hereafter also: “Bitpanda”). The reporting system is operated by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of Bitpanda.
Personal data and information entered into the reporting system are stored in a database operated by EQS Group in a high-security data centre. Only Bitpanda has access to the data. EQS Group and other third parties do not have access to the data. This is ensured in the certified procedure through extensive technical and organisational measures.
All data are stored encrypted with multiple levels of password protection so that access is restricted to a very small selection of expressly authorised persons at Bitpanda.
Questions on data protection and privacy can be sent to privacy@bitpanda.com.
4. Type of the collected personal data
Use of the reporting system takes place on a voluntary basis. If you submit a report via the whistleblowing system, we collect the following personal data and information:
- your name, if you choose to reveal your identity,
- whether you are employed at Bitpanda, and
- the names of persons and other personal data of persons that you name in your report.
5. Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the Compliance department of Bitpanda and are always handled confidentially. The employees of the Compliance department of Bitpanda will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduction of a special investigation, it may become necessary to share reports with additional employees of Bitpanda or employees of other group companies, e.g. if the reports refer to incidents in subsidiaries. The latter may be based in countries outside the European Union or the European Economic Area with different regulations concerning the privacy of personal data. We always ensure that the applicable data privacy regulations are complied with when sharing reports.
All persons who receive access to the data are obligated to maintain confidentiality.
6. Information of the accused person
As a basic principle we are bound by law to inform the accused persons that we have received a report concerning them, unless this threatens further investigations into the report. In doing so, your identity as whistleblower is not revealed as far as is legally possible.
7. Rights of the data subjects
According to European data protection law, you and the persons named in the report have the right to inquiry, rectification, erasure, restriction of processing and the right to object to processing of personal data concerning them. If the right of objection is claimed, we will immediately examine to what extent the stored data is still necessary for the processing of a report. Data that is no longer required is deleted immediately. In addition, you have the right to lodge a complaint with a supervisory authority, if you think your rights have been violated under the GDPR. In Austria, this is the Data Protection Authority (Datenschutzbehörde).
8. Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform an evaluation of the report or a legitimate interest of the company exists, or it is required by law. After the report processing is concluded, this data is deleted in accordance with the statutory requirements.
9. Use of the reporting portal
Communication between your computer and the reporting system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the reporting system. In order to maintain the connection between your computer and the BKMS® System, a cookie is stored on your computer that merely contains the session ID (a so-called session cookie). This cookie is only valid until the end of your session and expires when you close your browser.
It is possible to set up a postbox within the reporting system that is secured with an individually chosen pseudonym/ username and password. This allows you to send reports to the responsible employee at Bitpanda either by name or in an anonymous, safe way. This system only stores data inside the reporting system, which makes it particularly secure. It is not a form of regular e-mail communication.
10. Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible employee of Bitpanda. If you wish to submit an anonymous report, please take note of the following security advice: Files can contain hidden personal data that could compromise your anonymity. Remove this data before sending. If you are unable to remove this data or are unsure how to do so, copy the text of your attachment into your report text or send the printed document anonymously to the address listed in the footer, citing the reference number received at the end of the reporting process.
11. How to contact us?
Thank you for reading our Privacy Policy!
If you have any further questions about this Privacy Policy or the processing of your personal data, please contact our privacy team: privacy@bitpanda.com