How we treat your personal data…

What is Slush Pool?

A Slush Pool is a virtual currency mining pool. The mining pool is used to combine the computational resources of multiple individual virtual currency miners to optimize their individual efforts of finding a block.

The Slush Pool platform is available on our Website https://slushpool.com, where you may also find more information about the Slush Pool and pooled virtual currency mining (the “Website”).

Your participation in the Slush Pool is governed by the General Terms and Conditions of Slush Pool available on our Website.

Why should I read this document?

You may have heard about Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the ”Regulation”) more commonly known as GDPR. 

Under the Article 13 and 14 of the Regulation, we must provide our customers and other data subjects with information on the collection, handling, protection and processing of their personal data.

Therefore, in this Privacy Policy you may learn more about these topics regarding among others the personal data that we collect when developing Slush Pool, when providing the Slush Pool experience to our customers, when communicating with our customers and when providing our customers with any related support (technical or other).

When we mention the term customers in this document again, we refer to miner - legal entities or individuals, who provide their computing power to the Slush Pool virtual currency mining pool.

Who collects my personal data?

We are a commercial company called Braiins Systems s.r.o., with its registered office at Křižíkova 148/34, Karlín, Prague 8, Czech Republic, Id. No. 241 47 931, registered in the commercial register kept by the Municipal Court in Prague under file No. C 183056.

We are the operator of the Slush Pool, which means we secure the operation and further development thereof.

What personal data do you process?

Personal data processed for development

To develop and test virtual currency mining platform we collect, store and process analytical and other data related to virtual currency mining that may sometimes be considered as personal data within the meaning of the Regulation. Such data may include, without limitation, for example following information:

  • username; 

  • email address; 

  • password in hashed form; 

  • wallet address; 

  • IP address, including IP address or another identifier of mobile phone or other device used to access the platform; 

  • other data voluntarily provided via the user account and in fulfilment of the mutual rights and obligations.

  • information about your devices (such as unique device ID);

  • information and statistics relating to the amount of computing power you provide to the Slush Pool platform;

  • information about your rewards and processed payouts.

Sometimes we use our own materials and sources to obtain necessary data and sometimes we use third party analytical and other data (obtained from public sources such as internet or via telemetry from customers using our services - for example, when you report an issue and initiate a support procedure, we may use the acquired information for further development of the Slush Pool). 

In all above-mentioned cases some of the information that we collect, store and process for development may be considered as personal data. In that event, we will, as a data controller collect, store and process such personal data.

Personal data collected via communication

On our Website we provide you with our contact information, so you can contact us, request information about our products and our company or notify us of any issues with the services that you use. 

If you, during the course of our communication, send us any information that may be considered as personal data (such as first and last name, email address, IP address etc.), we will, as a data controller, collect, store and process such personal data.

Personal data collected when using Slush Pool

We collect, store and process the information you provide us in relation to the use of our platform, the conclusion of a contract on the provision of computing power and also via the interface of your user account. 

Therefore, we collect, store and process the following information you provide when registering or editing your user account: 

  • username; 

  • email address; 

  • password in hashed form; 

  • wallet address; 

  • IP address, including IP address or another identifier of mobile phone or other device used to access the platform; 

  • other data voluntarily provided via the user account and in fulfilment of the mutual rights and obligations.

When you provide your computing power to the Slush Pool platform, we may collect and process telemetric and other data related to your mining activities. Such data may include, without limitation, the following information:

  • information about your devices (such as unique device ID);

  • information and statistics relating to the amount of computing power you provide to the Slush Pool platform;

  • information about your rewards and processed payouts.

If any of the above-mentioned information are considered as personal data, we will, as a data controller, collect, store and process such personal data.

We would like to remind you that under some laws you may be, as a miner of virtual currencies considered as a personal data controller as well and may be subject to some rules and obligations yourself. If at any time you are not sure, do not hesitate to ask us for more detailed information.

Personal data collected when providing support services

We may provide our customers support services regarding their participation in the virtual currency mining pool. 

To be able to provide you with any support services we may have to use telemetric data collected when you use your device and any additional data obtained from you during the course of support procedure (such as your contact information, your logs etc.).

If any of such information are considered as personal data, we will, as a data controller, collect, store and process such personal data.

Cookies

On our Website we use a variety of cookies. Some of the cookies may be used to collect personal data of our customers.

For more information, please see the dedicated section of this Privacy Policy and Slush Pool Cookie Policy.

Why do you process my personal data?

Personal data processed for development

We collect, store and process the above-mentioned analytical data to develop and test the virtual currency mining pool.

To comply with legal requirements, we must mention that we collect, store and process such personal data pursuant to Article 6 (1)(f) of the Regulation. 

That means that it is in our legitimate interest to collect, store and process such personal data, since there is no other effective way to address issues of our software and hardware if we cannot use the data acquired when providing you with our services and since we also make sure that it represents little to no restriction of data subject interests, rights and freedoms. 

It is also in our legitimate interest to collect, store and process such personal data to establish, exercise or defend any related legal claims, since otherwise we could not exercise our legal rights and such use of personal data is foreseeable by data subjects and represents little to no restriction of data subject interests, rights and freedoms. 

Personal data collected via communication

We collect, store and process the personal data collected via communication with you for the purpose of providing you with requested products, services, support or any other information, for the purpose of exercising any rights and fulfilling any obligations related thereto as well as for the purpose of any further communication with you. 

To comply with legal requirements, we must mention that we collect, store and process such personal data mainly pursuant to Article 6 (1) (b) of the Regulation (it means that processing is necessary for the performance of a contract to which you are a party or in order to take steps prior to entering into such contract).

We collect the information provided by you through the contact form also for marketing purposes, for example to inform you about our latest products, services and features, and to establish, exercise or defend any related legal claims. 

To comply with legal requirements, we must mention that we collect, store and process such personal data pursuant to Article 6 (1)(f) of the Regulation. 

That means that it is in our legitimate interest to collect, store and process such personal data for marketing purposes, since it is in our interest to inform our customers about such news and it is reasonable to expect that the customers that have contacted us before may be interested in such news. Additionally, the customers may at any time opt out from receiving such news.

It is also in our legitimate interest to collect, store and process such personal data to establish, exercise or defend any related legal claims, since otherwise we could not exercise our legal rights and such use of personal data is foreseeable by data subjects and represents little to no restriction of data subject interests, rights and freedoms. 

Personal data collected when using Slush Pool

We collect, store and process your personal data only so we can provide you services pursuant to the General Terms and Conditions of the Slush Pool and to further develop our services.

We will specifically process your personal data

  • to fulfil any of our obligations under the above-mentioned terms and conditions and any applicable law and to protect our own rights thereunder;

  • to secure the quality of our services and to use it for other commercial purposes including informing you of products and services related to Braiins;

  • to use it for marketing purposes (research of quality).

To comply with legal requirements, we must mention that we collect, store and process such personal data mainly pursuant to the Article 6 (1) (b) and (f) of the Regulation.

For the legitimate interest explanation please read the section dedicated to the personal data collected via communication, since the similar legitimate interest rules apply.

Personal data collected when providing support services

We collect, store and process your personal data only so we can provide you with support services and to further develop our products.

We will specifically process your personal data

  • to fulfil any of our obligations when providing you with support services and the related obligations under any applicable law and to protect our own rights thereunder;

  • to secure the quality of our services and to use it for other commercial purposes including informing you of products and services related to Braiins;

  • to use it for marketing purposes (research of quality).

To comply with legal requirements, we must mention that we collect, store and process such personal data mainly pursuant to the Article 6 (1)(b) and (f) of the Regulation. 

For the legitimate interest explanation please read the section dedicated to the personal data collected via contact form, since the similar legitimate interest rules apply.

We collect, process and store your personal data only for the above defined purposes and only to the extent necessary to fulfill these purposes. We never conceal the purpose for which the personal data is collected and further processed.

For how long will you process my personal data?

We process and store your personal data only for the time necessary to meet the purposes of its processing specified above, or for the time consented by you, or for the time that is either necessary to comply with  our obligations under the applicable law or set forth by the applicable law or in accordance therewith. We comply with the mandatory rules for data archiving. 

Once the purpose of the personal data processing disappears, we will destroy the personal data.

Personal data processed for development

As for the personal data processed for development, we will process and store such personal data only for the period necessary to develop and test our virtual currency mining pool (we begin processing immediately after the data are collected) and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law,  or set forth by the applicable law or in accordance therewith.

Personal data collected via communication

As for the personal data voluntarily provided by you when you communicate with us, we will process and store such personal data until the requested issue is solved and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the requested issue.

Personal data collected when using Slush Pool

As for the personal data collected when you are using the Slush Pool we will process and store such personal data for as long as you use Slush Pool (for the duration of your user account) and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law, or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the provided services.

Personal data collected when providing support services

As for the personal data voluntarily provided by you when we provide you with our support services, we will process and store such personal data until the requested issue is solved and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law or set forth by the applicable law or in accordance therewith, or during which you or any third party may contest that we have broken any of our obligations or have violated any applicable laws in relation to the requested issue.

Who will have access to my personal data?

We take care of your personal data security and so we choose the partners to whom we entrust your personal data very carefully. 

All our partners must be able to provide sufficient security of your personal data to prevent unauthorized or accidental access thereto or other abuse thereof and all our partners must undertake a confidentiality obligation and must not use your personal data for any purpose other than the purpose for which the data were made available to them.

The recipients that may have access to your personal data are following:

  • persons who provide us with the technological services or technology operators that we use to provide our services;

  • persons who provide our services and Websites with security and integrity and who regularly test such security and integrity;

  • providers of accounting, legal and administrative services;

  • our staff.

Our aim is and always will be to ensure your personal data are as anonymous as possible and unavailable to all third parties. However, under certain specifically defined conditions we will be under some circumstances required, in accordance with the applicable law, to transfer certain personal data to public authorities.

Do you transfer the personal data outside the EU/EEA?

When collecting, storing and processing personal data we sometimes may use personal data processors such as Google or Cloudflare, which under some circumstances transmit your personal data to third countries. In such an event we always make sure such transmission is compliant with the Regulation. 

In particular, we specify that the personal data may be transmitted to the United States of America and in such event the transmission is compliant with the Standard Contractual Clauses (SCCs) mechanism.

How are my personal data protected?

All your personal data is secured by standard procedures and technologies. We provide data protection against unauthorized or accidental access, alteration, destruction, loss, unauthorized transmission or any other unauthorized processing, as well as against any other abuse of records containing the personal data. 

The standard procedures and technologies may include, but are not limited to, the following:

  • education and training of relevant staff to ensure they are aware of our privacy obligations when handling personal data;

  • administrative and technical rules to restrict access to personal data on a ‘need to know’ basis;

  • technological security measures, including firewalls, encryption and anti-virus software;

  • keeping the most sensitive personal data offline;

  • physical security measures, such as staff security passes to access our premises.

We are not able to guarantee the security of your personal data without your help and responsible behavior. Therefore, we ask you to help us ensure the security of your data by keeping in secret and secure your user account login information by following a common security standards.

Do you use cookies?

On our Website (and any subdomains thereof) we use cookies to analyze traffic and to personalize content and ads. 

We will, as a data controller, collect, store and process any information that are considered as personal data collected by such cookies (the personal data may include your IP address, information about your activity on our Website, information about your advertisement preferences etc.).

To comply with legal requirements, we must mention that we collect, store and process such personal data mainly pursuant to the Article 6 (1) (f) of the Regulation. 

That means that it is in our legitimate interest to collect, store and process such personal data for marketing purposes and for Website traffic analysis, since 

  • it allows us to improve our products and services and to provide you with personalized content and advertisement, 

  • some cookies also allow us to keep our website secure from various attacks and some cookies allow our website  to properly function,

  • we do not attempt to identify you using such personal data,

  • there is little to no restriction of your interests, rights and freedoms, and

  • you may at any time delete stored cookies permanently and change your cookie settings to disable or limit storage of any new cookies.

We will process and store such personal data for the period necessary to analyze traffic and to provide any personalized content to you and also for the subsequent period thereafter that is either necessary to comply with our obligations under the applicable law, or set forth by the applicable law or in accordance therewith.

Please, read our Slush Pool Cookie Policy available on our Website to learn more about the cookies that we use.


What are my rights in relation to personal data protection?

In relation to the personal data you shall have in particular the following rights:

  • a right to withdraw your consent at any time;

  • a right to correct or make additions to the personal data;

  • a right to request restrictions to processing of your personal data ;

  • a right to object or complain against processing of your personal data under certain circumstances;

  • a right to request transfer of your personal data ;

  • a right to access your personal data;

  • a right to be informed of the personal data security breach under certain circumstances;

  • a right to request deletion of your personal data (a right to be „forgotten“) under certain circumstances; and

  • other rights set forth in Act No. 110/2019 Coll., on personal data processing (Personal Data Protection Act) and the Regulation.

You have a right to object, on grounds relating to your particular situation, at any time to processing your personal data which is based on Article 6(1)(f) of Regulation (it means that we have legitimate interest to process such personal data). You have also a right to object to processing your personal data for direct marketing purposes.

Additionally, you have a right to contact the Office for Personal Data Protection with a request for remedial measures in case of any violation of the obligations set forth in the Regulation at the following address: Office for Personal Data Protection, Pplk. Sochorova 27, 170 00 Prague 7, Czech Republic, phone number +420 234 665 111 (central telephone exchange).

How can I contact you?

If you have any questions regarding this Privacy Policy, please do not hesitate to contact us using the contact details below:

Contract address: Křižíkova 148/34, Karlín, Prague 8, Czech Republic

Contact point (support): https://help.slushpool.com

Email address: info@braiins.com

When is this Privacy Policy effective? 

This Privacy Policy comes into effect on the 1st January 2020. 

We reserve the right to amend and update this Privacy Policy at any time.


In Prague on 1st January 2020
Braiins Systems s.r.o.