Organisation information

Registration country

United Kingdom

Registration number

09083955

Data Protection Officer

Organisations that use special categories of data, are public bodies, or do large scale processing must appoint a Data Protection Officer.

Email address

dpo@coinbase.com

Data categories collected

Organisations must give details about what categories of data are stored and processed.

Coinbase UK's privacy policy says they collect the following categories of data:

• Bank account details

• Bank transactions

• Date of birth

• Device information

• Email address

• Employment

• Gender

• Identity documents

• Names

• Online activity

• Postal address

• Telephone number

Unusual processing purposes

Organisations must provide information about what they do with data. This section highlights less common uses of data.

This privacy notice does not appear to mention any unusual processing purposes.

Third parties

Organisations must give details about other parties that personal data is shared with.

Coinbase UK's privacy policy says they share data with the following third parties:

List of third parties

• Identity verification services

• Service providers like bill collection, marketing, and technology services

• Financial institutions with which we partner to process payments you have authorised

• Companies or other entities that we plan to merge with or be acquired by

• Companies that purchase Coinbase assets under bankruptcy/insolvency law

• Law enforcement

How specific is this information?

Third parties are listed as groups

Our Observations

States that "CB will never sell or rent your personal information".

Retention rules

Organisations must give details about how long data is kept.

Summary

Basic contact information is kept until user unsubscribes.

Content like support desk comments, photographs, videos, blog posts may be kept indefinitely for audit and crime prevention purposes.

Phone call recordings are kept for up to 6 years.

Cookies, webpage counters, analytics tools are kept for up to one year from expiry of a cookie.

Our Observations

Coinbase use an email suppression list.

How specific is this information?

• Retention rules are given for specific categories of data

• Specific times are given for how long data is kept

Lawful bases

Organisations must justify collection and use of data under six lawful bases and provide information about their decisions

Coinbase UK's privacy policy says they use the following lawful bases to collect and use data:

• Contract

  CB handles very sensitive information, such as your identification and financial data, so it is very important for us and our customers that we are actively monitoring, investigating, preventing and mitigating any potentially prohibited or illegal activities, enforcing our agreements with third parties, and/or violations of our posted user agreement or agreement for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected on our Services for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform our Services in accordance with our terms.

• Legal obligation

  Some of our core Services are subject to laws and regulations requiring us to collect and use your personal identification information, formal identification information, financial information, transaction information, employment information, online identifiers, and/or usage data in certain ways. For example, Coinbase must identify and verify customers using our Services in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. In addition, we use third parties to verify your identity by comparing the personal information you provided against third-party databases and public records. When you seek permissions to raise Digital Currency buy and sell limits associated with your CB Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform the Services in accordance with legal and regulatory requirements.
  
  EEA Residents: For individuals who reside in the European Economic Area (including the United Kingdom) or Switzerland (collectively “EEA Residents”), pursuant to Article 6 of the EU General Data Protection Regulation (GDPR) or any equivalent legislation (collectively “EEA Data Protection Law”), we process this personal information to comply with our legal obligations.

Our Observations

Legitimate interests aren't clearly labelled, but these could include:

* To provide Coinbase’s Services
* To provide Service communications
* To provide customer service
* To ensure quality control
* To ensure network and information security
* For research and development purposes
* To enhance your website experience
* To facilitate corporate acquisitions, mergers, or transactions
* To engage in marketing activities

Security standards

Organisations must ensure that data is stored and processed securely.

Our Observations

Mentions "appropriate safeguards" but doesn't go into any detail beyond using Payment Card Industry Data Security Standards (PCI DSS).

How specific is this information?

This organisation provides specific details about how they secure data

Data processing addendum

Some organisations offer a data processing addendum that gives data adequate protections when it leaves the EEA.

Type

Adequate protections are provided by this organisations Terms of Service

Our Observations

Uses model contract clauses and EU-US Privacy Shield with international partners

Automated decision making

Organisations must give details about how data is used to make decisions without human involvement.

Complaint information

Organisations must give details about how to make a complaint with a data protection authority.

Summary

This privacy notice contains information about to make a complaint to a data protection regulator

Our Observations

Provides a clickable email address to casework@ico.org.uk.

How specific is this information?

This privacy notice contains specific contact details for a data protection regulator

Design recommendations

Organisations are required to provide privacy information in a transparent way. The Article 29 Working Party has provided recommendations on how to do this.

Assessment

This privacy notice:

• Has language that is easy to understand

• Is designed in a way that makes it easy to find information

• Can be easily found on the organisation's website